HFSS advertising restrictions
Final Review
Statement
Publication date:
26 July 2010
HFSS advertising restrictions – final review
Contents
Section
Page
1 Summary
1 2 Background
7 3 Data & Methodology
12 4 The changing context
17 5 Changes in the amount of HFSS advertising seen by children
30 6 Changes in the food and drink advertising techniques seen by
children
42 Annex
Page
1 BCAP Scheduling Rules
47 2 BCAP Content Rules
50 3 Channel & airtime definitions
56 4 Food and Drink definitions used in the review
59 5 Changes in children’s exposure to food and drink advertising
77 6 Changes in advertising impacts by different measures
83 7 Changes in the use of advertising techniques of appeal to
children
85 HFSS advertising restrictions – final review
Section 1
1 Summary
Introduction
1.1
This section describes the outcome of Ofcom’s final review into the effectiveness of
restrictions on advertising for products that are high in fat, salt or sugar (HFSS). It
compares the way in which the balance of television advertising of food and drink
seen by children has changed, by looking at their exposure to advertisements for
HFSS products in 2005 (before advertising restrictions were introduced) and in 2009
(after the restrictions had been fully implemented).
Background
1.2
In December 2003, amid growing concerns about child obesity, the Government
called for a change in the nature and balance of advertising food and drink products
to children. The then Secretary of State for Culture, Media and Sport asked Ofcom to
consider proposals for strengthening the rules on television advertising of food and
drink products to children. Government elaborated its policy objective in a White
Paper published by the Department of Health in November 2004, which said that
there was ‘a strong case for action to restrict further the advertising and promotion to
children of those foods and drinks that are high in fat, salt and sugar’.
1.3
In November 2006, following an extended period of analysis and consultation, Ofcom
announced a ban on the scheduling of HFSS advertising during children’s airtime1
and around programmes with a disproportionately high child audience. HFSS
advertising would continue to be allowed at other times. Ofcom’s principal aim was
‘to reduce the exposure of children to HFSS advertising, as a means of reducing
opportunities to persuade children to demand and consume HFSS products’2.
1.4
For this purpose, HFSS products were defined by reference to a nutrient profiling
model developed by the Food Standards Agency (FSA).The scheduling rules were
phased in from 1 April 2007 (see Annex 1 for the full set of scheduling rules). The
final phase came into force on 1 January 2009, when all HFSS advertising was
banned from children’s channels.
1.5
Ofcom estimated that the advertising restrictions, once fully implemented, would
reduce the exposure of 4-15 year olds to HFSS advertising by 41% of the 2005 level
(the last year for which we had comprehensive revenue and viewing data at the time)
and by 51% for younger children (4-9 year olds)3.
1.6
In parallel, the Advertising Standards Authority (ASA)4 introduced restrictions on
advertising techniques that may be used in promoting food and drink products,
including some specific to HFSS products. Section 2 summarises the nature of the
restrictions in more detail, and they are set out in full in Annex 2.
1 The periods within television schedules devoted to children’s programming, including all programming on
children’s channels - see Annex 3
2 Paragraph 1.9, Television advertising of food and drink products to children – Final statement, Ofcom, February
2007 (http://www.ofcom.org.uk/consult/condocs/foodads_new/statement/statement.pdf)
3
Television Advertising of Food and Drink Products to Children – statement and further consultation, Ofcom,
November 2006 (http://www.ofcom.org.uk/consult/condocs/foodads_new/foodads3.pdf)
4 The restrictions were codified by the Broadcasting Committee of Advertising Practice of the Advertising
.
Standards Authority – Ofcom’s co-regulator of TV and radio advertising
1
HFSS advertising restrictions – final review
1.7
In announcing the restrictions, Ofcom said that it would carry out a review in due
course to assess whether or not the restrictions were having the expected effects in
terms of:
a) the reduction in the amount of HFSS advertising seen by children;
b) the use of advertising techniques considered to appeal to children in HFSS
advertising; and
c) the impact on broadcasting revenues.
1.8
The Government asked Ofcom to carry out an interim review in 2008, before the final
phase of restrictions came into force. The key findings from this were that, during
2007/8, children5 saw around 34% less HFSS advertising than in 2005, with younger
children (4-9 year olds) seeing 39% less and older children (10–15 year olds) seeing
28% less6.
1.9
This final review looks at data from 2009, following the implementation of the final
phase of restrictions (a ban on all HFSS advertising on children’s channels) and
compares it with data for 2005 (prior to the introduction of the restrictions).
The changing context
1.10
To understand the significance of changes to the nature and balance of food
advertising to children, it is important to look at the context in which these changes
are occurring. We examine this in more detail in Section 4. The main contextual
changes between 2005 and 2009 are similar to those observed in the interim report
and are as follows:
a) children are watching broadly the same amount of television as in 2005 (around
16 hours a week), and the same proportion of viewing in commercial adult airtime
(just over half) and children’s airtime (around a third);
b) 93%7 of households with children had access to multichannel television in 2009
up from 76% in 2005. As a result, children’s viewing has shifted somewhat from
the main PSB channels to digital channels;
c) the main beneficiaries of this shift in children’s viewing habits have been
children’s channels (both commercial and non-commercial) and the commercial
PSB portfolio services (e.g. ITV2, Fiver and E4) where children’s viewing has
increased from 0.5 hours in 2005 to 1.6 hours per week in 2009 (0.6 hours to 2
hours for 10-15 year olds);
d) in line with TV advertising in general, the number of HFSS spots on television has
increased overall (mainly due to the proliferation of channels). However the share
of HFSS adverts as a proportion of all TV advertising has remained stable (10.0%
in 2005 compared to 9.8% in 2009); and
e) there has been a significant shift in the balance of food and drink advertising on
television. In 2005, we estimate over 22% of all food and drink advertising spots
were for non-HFSS products; by 2009, this had risen to over 33%.
5
Unless otherwise indicated, references to children are to those aged 4-15.
Changes in the nature and balance of food advertising to children, Ofcom, 17 December 2008
(http://www.ofcom.org.uk/research/tv/reports/hfssdec08/hfssdec08.pdf) (‘interim review)
7
Ofcom technology tracker data for Q1 2009
6
2
HFSS advertising restrictions – final review
Changes in the amount of HFSS advertising seen by children
1.11
For the reasons explained in Section 3, while the amount of food and drink
advertising can be directly measured, it is not possible to measure exactly how much
HFSS advertising there was in either 2005 or 2009. The best estimate of change
requires a comparison between separate assessments or ‘proxies’ of how much
HFSS advertising was seen by children in 2005, and how much they saw in 2009. It
is important to note that these assessments are prepared on different bases, and the
outcome is necessarily approximate and should not be taken as an exact indication.
1.12
On that basis, we estimate that overall, compared with 2005, in 2009:
a) children saw around 37% less HFSS advertising (i.e. a reduction of 4.4bn
impacts);
b) younger children (4-9 year olds) saw 52% less (3.1bn impacts); older children
(10–15 year olds) saw 22% less (1.4bn impacts);
c) overall, children saw 40% less HFSS advertising on the commercial PSB
channels(2.4bn impacts) 8 and 33% less advertising on commercial non-PSB
channels (2.0bn impacts). These reductions were driven by the decline in impacts
during children’s airtime. In adult airtime, children saw 28% (1.4bn impacts) less
HFSS advertising on the commercial PSB channels, but saw 46% (1.3bn
impacts) more advertising on commercial non-PSB channels. As a result children
saw 1% (0.1bn impacts) less HFSS advertising overall in adult airtime;
d) exposure to HFSS advertising was eliminated during children’s airtime (including
both children’s channels and children’s slots on other channels); and
e) despite an increase in the volume of HFSS advertising aired throughout the day,
children’s exposure to HFSS advertising fell in all day parts before 9pm and by
25% between the peak hours of 18:00-21:00.These reductions were driven by the
decline in impacts during children’s airtime.
1.13
It should also be noted that not all of the HFSS advertising seen by children is for
products that may appeal to them. Separate analysis carried out by Ofcom suggests
that overall just over 56% of all food and drink advertising seen by children was either
for non HFSS products or for HFSS products unlikely to appeal to them e.g. spreads,
cooking oil and drinks mixers etc.
1.14
Broadcasters complied with the restrictions on scheduling HFSS advertising during
children’s airtime. Ofcom is aware of two instances where an HFSS advert was
mistakenly aired during children’s airtime. By the same token, we found little
evidence that advertisers were evading the spirit of the restrictions, by airing
advertising and sponsorship during children’s airtime in the names of brands
commonly associated with HFSS products. The rules on scheduling HFSS
advertising apply equally to sponsorship bumpers. We have found only two
broadcasters in breach of the rules in relation to sponsorship between 2005 and
2009 (one on a UK service9 and a second broadcaster on two of its channels
licensed by Ofcom but targeted at Spain10). This resulted in the removal of the
8
ITV, Channel 4, Five, and in Wales S4C1
Broadcast Bulletin No. 128, Ofcom, 23 February 2009 (www.ofcom.org.uk/tv/obb/prog_cb/obb128/)
10
Broadcast Bulletin No. 147, Ofcom, 7 December 2009
(www.ofcom.org.uk/tv/obb/prog_cb/obb147/Issue147.pdf)
9
3
HFSS advertising restrictions – final review
sponsorship credits and, for one broadcaster, the implementation of additional staff
training.
Changes in the use of advertising techniques seen by children
1.15
As in the interim review, Ofcom has looked to ascertain what changes there have
been in the use of particular advertising techniques used in food and drink
advertising that have been defined as of particular appeal11 to children12. The
analysis includes advertisements for both HFSS and non-HFSS products.
1.16
Between Q1 2005 and Q1 2009:
a) children saw less advertising featuring licensed characters (-84%), brand equity
characters (-56%), other characters (-2%) and promotions (-41%);
b) children saw more advertising featuring celebrities (143%) and health claims
(18%). Almost all of the growth in exposure took place in adult airtime. In line with
the interim review, the majority of celebrities featured in these advertisements
appeared to be primarily of appeal to adults (e.g. Ian Botham, Gloria Hunniford);
c) in children’s airtime, use of all of these techniques (with the exception of
celebrities) declined, but continued to register a presence as they are sometimes
used to promote non-HFSS products; and
d) in adult airtime the use the use of licensed characters also fell, but the use of the
other assessed techniques rose.
1.17
Overall, our analysis continues to suggest that children are exposed to significantly
less HFSS advertising using techniques considered to be of particular appeal to
children.
1.18
Surveys carried out by the ASA between 2007 and 2009 show that broadcasters are
complying with the restrictions on advertising techniques that may be used in food
and drink advertising aimed at children. In its latest compliance survey13 the ASA
found that all of the food and drink advertisements shown on the 67 television
services (including regional ITV services) that were monitored complied fully with the
HFSS content restrictions.
Impact on broadcasters
1.19
In restricting the advertising that broadcasters could carry, Ofcom sought to avoid a
disproportionate impact on the revenues of broadcasters. Ofcom estimated that the
restrictions would, nonetheless, have an adverse affect on the advertising revenue
earned by broadcasters, although some would be able to mitigate that loss to a
greater or lesser extent.
1.20
The interim review found that the restrictions on HFSS food and drink advertising
were not the most significant factor affecting broadcasters in the period under review
11
See Annex 2
Findings are based on Q1 2005 and Q1 2009 data due to limited data availability for 2009. The interim review
used 12 month data for 2005 and 2007/8
13
Food and Soft Drink Advertising Survey 2009, ASA, 22 June 2010 (http://www.asa.org.uk/MediaCentre/2010/ASA-Food-and-Soft-Drink-Survey-2009.aspx).Two of the TV advertisements included in the survey
were found to be in breach of the BCAP code however these were not breaches of the content restrictions for
food and drink products.
12
4
HFSS advertising restrictions – final review
2005 -2007/8), but was not able to quantify the impact they had on broadcasting
revenues14.
1.21
For the final review, Ofcom sought views from broadcasters on whether they were
able to provide advertising revenue data for 2008-9 that would shed light on the
impact of the advertising restrictions. All of the broadcasters that responded indicated
that it would not be feasible to disentangle the impact of the restrictions from other
factors, such as the economic downturn.
Conclusions
1.22
Ofcom’s 2004 research review15 suggested that television has a relatively modest
impact on children’s food preferences, and is only one among a number of factors
affecting those preferences. Nonetheless, Ofcom and its co-regulatory partner the
Advertising Standards Association put in place rules on both the scheduling and the
content of HFSS advertising that are amongst the strictest in the world.
1.23
These restrictions have:
a) reduced children’s exposure to HFSS advertising significantly (37% overall),
particularly in the case of younger children (52%), who may be more susceptible
to the influence of advertising. In the case of older children, the reduction is less
marked (22%), and somewhat less than that observed in the interim review
(28%). However, this reflects the greater proportion of their viewing in adult
airtime, and a shift in their viewing towards channels carrying more HFSS
advertising;
b) led to a sharp drop in HFSS advertising featuring various advertising techniques
considered attractive to children, such as popular cartoon characters. While
advertisers continued to make use of celebrities, both in children’s and adult
airtime, most of these are likely to appeal principally to adults; and
c) contributed to a significant shift in the balance of food and drink advertising on
television towards non-HFSS products, which accounted for an estimated 33.1%
all food and drink advertising spots in 2009 as against 22.5% in 2005 and 41.1%
of all food and drink child impacts in 2009, as against 19.3% in 2005.
1.24
We are therefore satisfied that the restrictions have served to reduce significantly the
amount of HFSS advertising seen by children, and to reduce the influence of
techniques in HFSS advertising that are considered likely to be particularly attractive
to children.
1.25
Against this background, and given the public policy objectives Ofcom was asked to
take into account (see paragraph 1.2 above), we consider it appropriate to maintain
the current restrictions, but not to extend them, for the reasons Ofcom stated in
November 200616. Ofcom will therefore maintain the current restrictions, including:
a) a ban on advertising HFSS products in programmes made for children aged 4-15;
14
Changes in the nature and balance of food advertising to children, Ofcom, 17 December 2008 see web link
page 2
15
Children's food choices, parents' understanding and influence, and the role of food promotions. Report, Ofcom,
July 2004 (http:// stakeholders.ofcom.org.uk/market-data-research/tv-research/food_ads/)
16
Television Advertising of Food and Drink Products to Children – statement and further consultation, Ofcom,
November 2006 See link page 1
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HFSS advertising restrictions – final review
b) a ban on advertising HFSS products in programmes likely to be of particular
appeal to children aged 4-15;
c) a ban on sponsorship in the name of HFSS products in programmes made for
children or likely to be of particular appeal to them; and
d) restrictions on HFSS advertising targeting children of primary school age or
younger, including bans on the use of licensed characters and celebrities popular
with children, on health claims, and on promotional offers.
1.26
6
Given the resources that were required for the detailed analysis that was undertaken
for the interim and final reviews, we do not anticipate conducting a further review
unless there is clear evidence of a change in circumstances.
HFSS advertising restrictions – final review
Section 2
2
Background
Introduction
2.1
This section summarises:
a) Ofcom’s role in relation to the regulation of food and drink advertising on
television;
b) the concerns about obesity which gave rise to the consideration of restrictions on
certain types of food and drink advertising;
c) the restrictions that Ofcom phased in between 2007 and 2009; and
d) Ofcom’s plans for a final review.
Ofcom’s role
2.2
Ofcom is the independent regulator of television, radio, telecommunications and
wireless communications services in the UK. Part of our role is to set standards for
television advertising. All television broadcasters must comply with these standards
in relation to any advertising they transmit. In late 2004 we transferred the
responsibility for the Television Advertising Standards Code to the Advertising
Standards Authority (ASA), including the functions of complaints handling and code
policy development. However, under this co-regulatory scheme Ofcom still retains
ultimate responsibility for all television advertising standards as the backstop
regulator under the terms of the Communications Act 2003 (‘the Act’). In particular,
Ofcom retains direct responsibility for advertising scheduling policy.
2.3
The relevant objectives to be secured by these standards include protecting under
18’s, and preventing the inclusion of harmful advertising and unsuitable sponsorship.
In setting these standards Ofcom must have regard, amongst other things, to the
degree of harm and offence likely to be caused by the inclusion of any sort of
material, the likely size and composition of the audience and to the vulnerability of
children. Ofcom must also take into account its principle duty to further the interests
of citizens and consumers, and must secure among other things the maintenance of
a sufficient plurality of providers of different television services and the availability of
a wide range of television services of high quality and calculated to appeal to a
variety of tastes and interests. In imposing regulatory measures Ofcom has to act in
a proportionate and targeted manner.
2.4
As well as setting standards to secure these objectives, the Act permits Ofcom to set
standards which prohibit certain advertisements and forms and methods of
advertising or sponsorship.
Concerns about obesity
2.5
A growing body of research17 has generated concerns in government and society
about rising childhood obesity levels and ill-health due to dietary imbalance,
17
See for instance: Tackling Obesity in England, National Audit Office, 2001; Annual Report of the Chief Medical
Officer, 3 July 2003; Obesity Statistics, 12 December 2005.
7
HFSS advertising restrictions – final review
specifically the over-consumption of food and drinks high in fat or salt or sugar
(HFSS) and the under-consumption of fresh foods, fruit and vegetables. Both the
Department of Health and the Food Standards Agency (FSA) identified television
advertising as an area where action should be considered to restrict the promotion of
HFSS foods to children.
2.6
In December 2003, the then Secretary of State for Culture, Media and Sport asked
Ofcom to consider proposals for strengthening the rules on television advertising of
food aimed at children.
2.7
In response, in early 2004, Ofcom conducted research into the role that television
advertising plays in influencing children’s consumption of foods that are HFSS18. In
publishing its research report in July 2004, Ofcom concluded that advertising had a
modest, direct effect on children’s food preferences and a larger but unquantifiable
indirect effect on children’s food preferences, consumption and behaviour. Ofcom
therefore concluded that there was a case for proportionate and targeted action in
terms of rules for broadcast advertising to address the issue of childhood health and
obesity. However, Ofcom also noted that one of the conclusions from the
independent research was that multiple factors account for childhood obesity.
Television viewing/advertising is one among many influences on children’s food
choices. These other factors include social, environmental and cultural factors, all of
which interact in complex ways not yet well understood. In these circumstances,
Ofcom considered that a total ban on food advertising would be neither proportionate
nor, in isolation, effective.
2.8
In November 2004, the Department of Health published a White Paper19 reiterating
the then Government’s view that there was ‘a strong case for action to restrict further
the advertising and promotion to children of those foods and drinks that are high in
fat, salt and sugar’ in both the broadcasting and non-broadcasting arenas. It made
clear that the then Government sought a ‘change in the nature and balance of food
promotion’.
2.9
At the same time the FSA published a consultation on a scheme which would identify
HFSS food and drink products by means of nutrient profiling. This model was
intended to help Ofcom reach decisions on the restriction of television advertising for
less healthy foods. In December 2005, the FSA completed their work on a nutrient
profiling scheme and provided it to Ofcom20.
2.10
In March 2006 Ofcom proceeded to consult on a range of different options for new
restrictions on television advertising to children (‘the March 2006 consultation
document’)21.
18
The full set of research documents published in 2004 can be found at Children's food choices, parents'
understanding and influence, and the role of food promotions. Report Ofcom, July 2004 see page 5 for web link
19
Paragraph 58, Chapter 2. Choosing Health: Making Healthier Choices Easier, Department of Health,
November 2004
(http://www.dh.gov.uk/en/publicationsandstatistics/publications/publicationspolicyandguidance/browsable/DH_49
55568)
20
An explanation of this model can be found on the FSA’s website at
http://www.food.gov.uk/healthiereating/advertisingtochildren/nutlab/nutprofmod
21
Television advertising of food and drink products to children - Options for new restrictions, Ofcom, March 2006
(http://www.ofcom.org.uk/consult/condocs/foodads/).
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HFSS advertising restrictions – final review
The advertising restrictions
Scheduling restrictions
2.11
Following that consultation, Ofcom published a Statement and Further Consultation
on 17 November 200622 (‘the November 2006 statement’), setting out a number of
decisions, and consulting on whether to extend restrictions on HFSS advertising in
children’s programming to cover programmes of appeal to under 16s.
2.12
In February 2007, Ofcom published its final statement (‘the February 2007
statement’)23. In that document, Ofcom concluded that, in the context of its statutory
duties, the aims of further regulation in relation to television advertising should be to
balance the following regulatory objectives:
a) reduce significantly the exposure of children under 16 to HFSS advertising, as a
means of reducing opportunities to persuade children to demand and consume
HFSS products;
b) enhance protection for both older and younger children as well as parents by
appropriate revisions to advertising content standards, so as to reduce children’s
emotional engagement with HFSS advertisements, and reduce the risk that
children and parents may misinterpret product claims, and to reduce the potential
for pester power;
c) avoid disproportionate impacts on the revenue of broadcasters;
d) avoid intrusive regulation of advertising during adult airtime, given that adults are
able to make informed decisions about advertising messages; and
e) ensure that any measures that are put in place are appropriate and sufficiently
timely to enable Government to observe changes to the nature and balance of
food promotion by early 2007.
2.13
Ofcom also concluded that:
a) with effect from 1 April 2007, advertisements for HFSS products should not be
shown in or around programmes aimed at children (including pre-school
children), or in or around programmes that were likely to be of particular appeal to
children aged 4-9; and
b) with effect from 1 January 2008, HFSS advertisements should not be shown in or
around programmes that are likely to be of particular appeal to children aged 41524.
2.14
An exception was made for children’s channels, to which the following transitional
arrangements were applied:
22
‘Television Advertising of Food and Drink Products to Children – Statement and Further Consultation’ , Ofcom,
November 2006 (‘November 2006 statement’)
(http://www.ofcom.org.uk/consult/condocs/foodads_new/foodads3.pdf)
23
Television Advertising of Food and Drink Products to Children: Final statement, Ofcom, February
2007.(http://www.ofcom.org.uk/consult/condocs/foodads_new/statement/)
24
A programme of particular appeal to children under 16 would be deemed to be one that attracted an audience
index of 120 for this age group. If a programme attracts an under-16 audience in a proportion similar to that
group’s presence in the population as a whole, it is said to index at 100. So an index of 120 is an overrepresentation of that group by 20%.
9
HFSS advertising restrictions – final review
a) for the period from 1 April 2007 until 31 December 2007, not more than 75% of
the average minutage devoted by that channel to HFSS advertising in the
calendar year 2005 was to be allowed;
b) for the period from 1 January 2008 to 31 December 2008, not more than 50% of
the average minutage devoted by that channel to HFSS advertising in the
calendar year 2005 was to be allowed; and
c) from 1 January 2009 onwards, all HFSS advertising to be excluded from
children’s channels.
Content restrictions
2.15
Alongside the scheduling restrictions, changes were introduced to BCAP’s rules on
the content of advertisements for food and drink products including some rules
specific to HFSS products. Amongst other things, the rules (reproduced in full in
Annex 2) now:
a) prohibit advertisements from encouraging excessive consumption of any food
and drink product, and require that portion sizes shown are relevant, particularly if
children are involved;
b) prohibit advertisements that seek to sell by appealing to emotions such as pity,
fear, loyalty or self-confidence or suggest that having the advertised product
somehow confers superiority, for example making a child more confident, clever,
popular, or successful; and
c) prohibit the use in HFSS product advertisements targeted directly at pre-school
or primary school children of:
i)
promotional offers (e.g. free toys);
ii) nutritional and health claims;
iii) licensed characters; and
iv) celebrities.
Reviews
2.16
At the request of the then Government, Ofcom carried out an interim review in 2008.
The review drew on data from July 2007 to June 2008 (the most recent 12 month
period for which data was available) and was published in December 2008. The key
findings from this were that, during 2007/8, children saw around 34% less HFSS
advertising than in 2005, with 4-9 year olds seeing 39% less and 10–15 year olds
seeing 28% less25.
2.17
Ofcom also concluded that in order to assess the full effect of the restrictions it would
be necessary to conduct a further review once full year data for 2009 was available.
As in the 2008 interim review, the 2010 final review assesses:
25
Changes in the nature and balance of food advertising to children, Ofcom, 17 December 2008 see web link
page 2
10
HFSS advertising restrictions – final review
a) whether scheduling restrictions have achieved the objective of reducing
significantly the number of HFSS product advertising impacts (i.e. each occasion
when a viewer sees an advert) among children aged 4-15 years;
b) whether scheduling restrictions and revised content rules are being implemented
as intended, or whether unexpected difficulties have emerged in interpretation,
implementation and enforcement;
c) whether the impact on broadcasters has been broadly consistent with the effects
that both Ofcom and the broadcasters expected;
d) whether advertisers are evading the spirit of the restrictions, by airing advertising
and sponsorship in the names of brands commonly associated with HFSS
products (rather than advertising the products themselves) in children’s airtime;
and
e) whether advertisers have significantly increased the amount of HFSS advertising
and sponsorship in periods outside children’s airtime, at times when significant
numbers of children may be watching.
Related issues
FSA’s review of nutrient profiling scheme
2.18
As the November 2006 statement noted, the FSA committed to a review of the
nutrient profiling model after a year of operation. In 2009 the FSA, having taken into
account the recommendations of the independent Nutrient Profiling Review Panel
concluded that no changes should be make to the nutrient profile model.
ASA’s reviews of advertising code
2.19
During July 200726, September 200827, and October 200928, the ASA carried out
assessments of whether broadcasters were complying with the new content rules.
The ASA examined food and soft drink television advertisements appearing across a
variety of media, including television. Section 6 reports on the outcome of these
reviews, and on the most recent review, published in June 2010.
26
Food and Soft Drink Advertising Survey 2007 Advertising Standards Authority, Jan 2008
http://www.asa.org.uk/MediaCentre/2010/~/media/Files/ASA/Reports/FoodandSoftDrinkAdvertisingSurvey2007.ashx
27
Food and Soft Drink Advertising Survey 2008 Advertising Standards Authority, Nov 2008
http://www.asa.org.uk/Media-Centre/2010/~/media/Files/ASA/Reports/FoodandSoftDrinkSurvey2008.ashx
28
Compliance report: Food and Soft Drinks Advertising Survey 2009, Advertising Standards Authority, 22 June
2010. See web link page 4.
11
HFSS advertising restrictions – final review
Section 3
3 Data & Methodology
Introduction
3.1
This section explains the data sources and key definitions used in analysing and
reviewing:
a) the changing context in which the advertising restrictions apply;
b) changes in the balance of food and drink advertising seen by children;
c) changes in the nature and balance of food and drink advertising.
3.2
For most purposes, we have tracked changes between 2005 (the last full year for
which Ofcom had data when finalising decisions on advertising restrictions) and 2009
(the first year in which the restrictions were fully implemented). In our November
2006 consultation document and February 2007 statement, we used 2005 as the
base year from which to estimate the effects of the advertising restrictions.
3.3
Although Ofcom’s advertising restrictions did not come into effect until April 2007, the
then Government made clear its intention to seek changes to the nature and balance
of food advertising across all media in 2003. In order to set the changes between
2005 and 2009 in context, we have provided data in Section 4 (‘The changing
context’) and Annex 5 (‘Changes in the balance of food and drink advertising seen by
children’) from 2003.
3.4
It should be noted that some of the figures in the text of the review differ slightly from
those in the graphs; this is due to the rounding of very large numbers in the graphs.
Data definitions: Glossary of terms
3.5
The following terms are used in the review:
a) ‘120 indexing’ and similar terms refer to the method used to determine whether a
programme appeals disproportionately to a particular demographic group, in this
case children. A programme of particular appeal to children under 16 is deemed
to be one that attracts an audience index of 120 for this age group. If a
programme attracts an under-16 audience in a proportion similar to that group’s
presence in the population as a whole, it is said to index at 100. So an index of
120 is an over-representation of that group by 20%;
b) the ‘2005 HFSS proxy’ is the approach we used to estimate the amount of HFSS
advertising in 2005, in the absence of actual data on what was HFSS advertising.
It is explained in more detail in Annex 4;
c) the ‘2009 HFSS proxy’ is the approach we have used to estimate the amount of
HFSS advertising in 2009, taking account of advertising that had been certified as
non-HFSS, and assessments of the remaining uncertified advertisements. It is
explained in detail in Annex 4;
d) ‘adult airtime’ means the periods within television schedules that do not consist of
children’s programming;
12
HFSS advertising restrictions – final review
e)
an ‘advertising impact’ is measure of viewing to a commercial spot. For example
ten impacts could be achieved by ten people viewing a single advertisement, by
one person seeing the advertisement ten times, or by five people seeing the
advertisement twice etc. In this review, impacts are added together to give a
measure of children’s exposure to particular types of advertising. As such, it is a
broad measure of advertising exposure. It is possible to segment impacts in
various ways, such by age band, time of day, channel or group of channels etc;
f)
‘advertising spot’ means one occasion on which an advertisement is broadcast;
g) ‘BARB’ or the British Audience Research Bureau is the industry body that collects
audience data for channels;
h) ‘BBC portfolio channels’ refers to BBC channels other than the analogue
channels (i.e. BBCs 1 and 2). Specifically, this includes BBC3, BBC4, BBC News,
BBC Parliament, CBBC and CBeebies. CBBC and CBeebies have in some
instances in this report been separated out to highlight trends across channels
dedicated to children’s programming;
i)
‘children’s airtime’ means the periods within television schedules devoted to
children’s programming, including all programming on ‘children’s channels’ (see
detailed definition in Annex 3);
j)
‘children’s channels’ are the channels listed in Annex 3;
k) ‘Clearcast’ (formerly the Broadcast Advertising Clearance Centre) is the body
which checks advertisements on behalf of most broadcasters to ensure that they
comply with relevant advertising regulations29. It requires advertisers to certify
food and drink advertisements using the nutrient profiling scheme devised by the
FSA if they wish to have their advertisements scheduled during restricted
periods;
l)
‘Commercial non-PSB channels’ means all non-BBC channels available on the
multichannel platforms. While it is possible some of these channels do not carry
commercial advertising (e.g. some Disney channels), this terminology has been
used for ease of comparison with BBC channels; ‘commercial PSB channels’
refers to the following advertising-funded public service channels - ITV1, Channel
4, Five, and in Wales, S4C1;
m) ‘commercial PSB portfolio channels’ are those commercial non-PSB channels
launched by the ‘commercial PSB channels’, such ITV2, E4 and Fiver;
n) ‘dayparts’ means the following periods within television schedules that have been
used in this review to understand in more details trends in advertising activity
over the course of a day: 06:00-09:30, 09:30-12:30, 12:30-15:15, 15:15-17:00
17:00-18:00, 18:00-21:00, 21:00-22:30, and 22:30–06:00;
o) ‘food and drink advertising’ is used to refer to the relevant product categories
(sometimes referred to in previous Ofcom publications as ‘core categories’) used
by Nielsen Media and Billetts Media to define advertising for all food and drink
products. Though broadly equivalent, the Nielsen and Billetts categories differ
slightly, as explained in Annex 4;
29
More information on Clearcast can be found at its website (www.clearcast.co.uk).
13
HFSS advertising restrictions – final review
p) ‘HFSS’ means food and drink products high in fat or salt or sugar, according to
the nutrient profiling scheme (see definition below) developed by the FSA;
q) ‘main PSB channels’ refers to the following public service channels - BBC One,
BBC Two, ITV1, Channel 4, Five, and in Wales, S4C1; and
r) ‘nutrient profiling’ is the method devised by the FSA to categorise food and drinks
products, for the purposes of TV advertising restrictions, as healthy or less
healthy30.
The changing context
3.6
We have used Ofcom data on trends in the penetration of multi-channel television
over time, and specifically within households where children are present. This data is
particularly useful for understanding changes in viewing behaviour as a result of the
increased choice available to audiences.
3.7
Using audience data from the British Audience Research Bureau (BARB), we have
looked at changes in the amount of television that children watch, the types of
channels they watch, and how much of their viewing takes place during children’s
airtime and other times of the day.
3.8
In looking at trends in television advertising for food and drink products in Section 4,
we have used data from Nielsen Media31 based on viewing data collected by BARB.
There are two data measures that have been sourced from this database – ‘spots’
which are a measure of the number of commercials aired and ‘impacts’ which provide
a measure of the amount of advertising seen. See definitions above.
Changes in the amount of HFSS advertising seen by children
3.9
In Section 5, we look at any changes there have been in children’s exposure to food
and drink advertising overall, and to advertising for HFSS and non-HFSS products.
3.10
The base year for measuring change in HFSS impacts is 2005. At that point,
advertising had not been formally classified as either HFSS or non-HFSS, as the
nutrient profiling scheme had not been finalised or implemented. We have carried out
separate assessments (‘proxies’) of how much HFSS advertising was seen by
children in 2005 and in 2009. This review contains assessments based on three
measures.
Food and drink (identified as ‘Core Categories’ between 2004 and 2007)
3.11
This measure includes advertising of all food products, soft drinks, beverages and
chain restaurants (fast food) as classified within the Nielsen Media database. It
should be noted that by definition ‘food and drink’ includes both HFSS and non-HFSS
products.
2005 HFSS proxy
3.12
For the purposes of the modelling undertaken in 200632 to estimate the amount of
HFSS advertising seen by children in 2005, we aggregated data from the Nielsen
30
An explanation of this model can be found on the FSA’s website at
http://www.food.gov.uk/healthiereating/advertisingtochildren/nutlab/nutprofmod
31
www.nielsenmedia.co.uk/
32
Documents can be found at http://www.ofcom.org.uk/consult/condocs/foodads_new/
14
HFSS advertising restrictions – final review
food and drink minor product categories (e.g. Food - Bakery goods - Biscuits)
considered most likely to be comprised wholly or mainly of HFSS products, having
regard to the FSA’s provisional nutrient profile model33. The resulting proxy (the
‘2005 HFSS proxy’) was inevitably broad brush in nature, as some of the subcategories included both HFSS and non-HFSS products. Nevertheless, it
represented the best estimate at that time of HFSS impacts.
3.13
To allow for detailed comparisons between 2005 and 2009 data to be made
(including HFSS spot data) it has been necessary to re-run the 2005 data for this
review. Changes to the Nielsen data base and Ofcom’s decisions on how to
categorise the resulting data (explained in Annex 4) has meant that the 2005 HFSS
base figure used in this review is 0.4bn impacts smaller (at 12.1 billion impacts) than
the 12.5bn impact base figure reported in the interim review. The lower 2005 base
figure means that any comparison with the 2009 data will show slightly smaller
reductions in HFSS impacts than would be the case if it had been possible to make
comparisons with the original 2005 data.
2009 HFSS proxy
3.14
With the introduction of nutrient profiling, it has been possible to make more robust
estimates of the amount of food and drink advertising that is for HFSS and non-HFSS
products. This estimate (the ‘2009 HFSS proxy’) is based on:
a) certificates for some advertisements provided by advertisers to Clearcast
indicating that they were for non-HFSS products;
b) classifications of generic products (e.g. milk, bread, fruit) as HFSS or non-HFSS
according to the FSA’s conclusions on nutrient profiling; and
c) judgements about the remaining product advertisements, based on the
certification or classification of products with similar or identical ‘brand’ labels
(see below for details).
3.15
The sheer volume of data for individual advertisements, coupled with the fact that
some were not certified as either HFSS or non-HFSS, required that we aggregate
individual advertisements by product type, and determine whether advertising for
products categories should be treated as HFSS or non-HFSS. This approach was
necessary for both the interim and final reviews and meant we were able to
aggregate the 2009 data at a more granular level than was possible for the 2005
data. Thus, we were able to categorise advertising at ‘brand’ level as defined by
Nielsen Media (e.g. Fox’s - Golden Crunch Biscuits) rather than at the broader level
of Nielsen’s minor product categories (e.g. Food - Bakery goods - Biscuits).For more
details on the treatment of brands in the 2009 HFSS proxy see Annex 4.
3.16
Some brand categories exclusively contain HFSS or non-HFSS advertisements. But,
as explained in Annex 4, where there are both HFSS and non-HFSS advertisements
within a single brand category, we have treated all such advertising as HFSS unless
there are strong indications that most are non-HFSS. Inevitably, this has meant that
some HFSS advertising has been treated as non-HFSS; however, we believe that
this is more than offset by the amount of non-HFSS advertising counted as HFSS
advertising, because it shares the same brand category. The effect of this
conservative approach is to underestimate the likely reduction in HFSS advertising
seen by children.
33
In doing so, we took advice from the Institute of Practitioners of Advertising.
15
HFSS advertising restrictions – final review
3.17
The net result of this approach is that, with one exception, none of the advertising in
children’s airtime is counted as being for HFSS products. The exception concerns
McDonald’s advertising for non-HFSS products within the brand category
“McDonald’s Chain Restaurants”34, which are sometimes shown in children’s airtime.
It would be misleading to count these as HFSS advertising; indeed, they are certified
as being for non-HFSS products. Accordingly, we have treated them as such.
Measuring Change
3.18
The analysis undertaken to arrive at the 2009 HFSS proxy demonstrated that
applying the 2005 proxy to 2009 advertising data would significantly overstate the
amount of HFSS advertising seen by children in 2009. The main reason for this is
that the 2005 proxy is based on entire sub-categories, rather than the more granular
approach taken in the 2009 proxy which is based on individual ’brands’. As the
equivalent information at a ‘brand’ level is not available for commercials aired in 2005
it is not possible to create a similar ‘brand’ level proxy for 2005 commercial activity.
3.19
For the purposes of this review we have compared the best estimate for HFSS
impacts in 2005 (re-run 2005 HFSS proxy) with our best estimate of HFSS impacts in
2009 (2009 HFSS proxy) to assess change in HFSS impacts over that period.
Although this does not provide a like-for-like comparison of HFSS advertising, we
consider that it represents a better means of assessing change than any available
alternative.
Changes in the use of techniques in advertising seen by children
3.20
In Section 6, we have looked at the use of techniques considered to appeal to
children in food and drink advertising. This analysis is based on data sourced from
Billetts Media Monitoring35. As HFSS products were not defined and classified before
the advertising restrictions came into force in April 2007, the database covers all food
and drink advertising, rather than just HFSS products.
3.21
The food and drink categories within the Billetts database differ in some areas from
the definition of food and drink advertising used elsewhere in the review (based on
Nielsen Media data). See Annex 4 for an explanation of the differences. The
Department of Health commissioned bespoke categorisation of this advertising in
2006 to allow it to analyse changes in creative techniques used in food and drink
advertising across media over time. The database broadly contains all food and drink
product advertising from 2003 to March 2009. Data collection ceased after Q1 2009
(i.e. the first quarter of 2009), so our analysis compares data from Q1 2009 with data
from Q1 2005. Inevitably, the short time frame means there is a risk that the
seasonality of food and drink advertising and/or individual advertising campaigns
could have a disproportionately large impact on our findings, which should be
regarded as a snapshot, rather than as definitive evidence of trends.
3.22
Each advertisement included in the database has been coded according to the type
of creative technique used within it. Changes in the volume of advertising spots and
impacts for each creative technique can be analysed over time. It should be noted
that adverts may make use of more than one such technique, and so may be
counted more than once. For example, if a Frosties cereal advert included an offer
for children’s books, the advert would be counted twice; once for using the brand
equity character Tony the Tiger and once for including a promotion.
34
35
Nielsen terminology - ‘McDonalds – Restr Chain’
http://www.ebiquity.com/uk/billetts/
16
HFSS advertising restrictions – final review
Section 4
4
The changing context
Introduction
4.1
Changes in the television environment and in viewing patterns can affect children’s
exposure to food and drink advertising, so it is important to understand the nature of
these changes. For example, the growth in the number of households able to receive
multichannel television has increased choice for all viewers, including children.
Growth in viewing to commercial channels may result in increased exposure to
advertising, as may an increase in the number of commercials aired.
4.2
This section examines the growth in the availability of multichannel television in
households with children, as well as trends in children’s viewing habits and in the
amount and distribution of television advertising for all food and drink and HFSS
products. It also reports on changes in food and drink advertising expenditure across
all media. In general the 2010 data show a continuation of the trends revealed in the
2008 interim review.
Key findings
4.3
The main findings are that between 2005 and 2009:
a) the amount of time children spent watching television has been fairly consistent
at around 16 hours per week. The split in viewing between children’s airtime and
commercial adult airtime has also remained broadly stable;
b) the proportion of households with children with access to multichannel television
increased from 76% to 93%36. This has contributed to a shift in children’s viewing
from the main PSB channels to non-PSB channels (including BBC portfolio
channels);
c) in children’s airtime, viewing has moved away from the main PSBs to children’s
channels. This trend has been driven by younger viewers aged 4-9;
d) in adult airtime, there has been a significant shift in viewing from the main PSBs
to non-PSB channels, particularly amongst older children (10-15 year olds);
e) children’s viewing of commercial PSB portfolio channels (e.g. ITV2, E4 and Fiver)
increased from 30 minutes to 1.6 hours per week, pushing up their share of
children’s viewing from 3.1% to 9.8%. For 10-15 year olds the increase was 1.4
hours (up from 0.6 hours to 2 hours);
f)
36
as with all television advertising, the amount of HFSS advertising on television
has increased (mainly due to the proliferation of channels). However, HFSS
advertising as a proportion of all TV advertising has remained stable (falling
fractionally from 10% in 2005 to 9.8% in 2009);
Ofcom technology tracker data for Q1 2009
17
HFSS advertising restrictions – final review
g) while HFSS advertising activity has been removed from children’s airtime, the
number of spots37 during adult airtime increased across the day; and
h) there has been a shift in the balance of food and drink advertising on television.
In 2005, we estimate that 22.5% of all food and drink spots were for non-HFSS
products; by 2009, this had risen to 33.1%.
The television landscape
4.4
As Figure 1 shows, the take-up of multichannel television has increased steadily in
recent years. Penetration is higher among households with children than across all
households in general. The take-up of multichannel television by households with
children has increased from 76% in 2005 to 93% in 2009.
Figure 1: Take-up of multichannel television in the UK
Multichannel penetration
100%
91%
93%
83%
80%76%
93%
89%
82%
95%
91%
85%
Adults with
multichannel television
at home
73%
% adults
60% 64%
Adults in households
with children and
multichannel television
at home
40%
20%
0%
2005
2006
2007
2008
2009
2010
Source: Ofcom Technology Tracker, Q1 of each year
4.5
The growth in multichannel television take-up has led to greater choice for all
viewers, including children. Children in households with digital terrestrial services
have access to three dedicated children’s channels (CITV, CBBC, CBeebies) while
those in cable and satellite homes may have access to over 20 dedicated children’s
channels38. By contrast, children with access only to the main PSB channels now
have access to a much reduced volume of children’s programming.
4.6
There has also been a rise in the number of channels of all genres over recent years.
A key trend has been the growth in portfolio channels launched by all the main PSB
channels (e.g. BBC3, ITV4, E4 and Fiver), as well as an increase in the number of
time-shifted channels.
37
38
See section 3.5 (e) for definition
including time-shifted channels
18
HFSS advertising restrictions – final review
Changes in children’s viewing habits
Figure 2: Average weekly hours of television viewing – Children by age group
Average weekly hours of television viewing
Average hours of viewing per week
20
16
Children 4-15
12
Children 4-9
8
Children 10-15
4
0
2003
2004
2005
2006
2007
2008
2009
Source: BARB
4.7
The total time children spend watching television between 2005 and 2009 remained
fairly stable at around 16 hours per week (Figure 2). On average, younger children
(4-9 year olds) saw slightly more (16.5 hours) than 10-15 year olds (15.6 hours) in
2009.
Children’s viewing by channel type
Figure 3: Split in children’s viewing by channel type
Total weekly viewing to main PSB and non-PSB channels: Children 4-15
17.2
Proportion of viewing, %
34.8%
16.8
15.8
15.4
15.6
39.3%
42.5%
46.8%
48.0%
16.2
51.8%
16.0
54.0%
Av. weekly hours of TV viewing
Commercial non-PSB
channels
Commercial PSB
channels
30.8%
30.4%
29.1%
26.1%
23.6%
BBC portfolio channels
22.0%
21.1%
9.6%
10.0%
4.1%
5.3%
30.3%
2003
25.0%
2004
6.4%
7.4%
8.9%
22.0%
19.7%
19.5%
16.6%
14.9%
2005
2006
2007
2008
2009
BBC One & BBC Two
Source: BARB
Note: Minor variations due to rounding
‘Commercial channels’ include all non-BBC channels and will include channels such as Disney which do not carry any commercial advertising
27
19
HFSS advertising restrictions – final review
4.8
Children’s viewing patterns by channel changed as their viewing shifted away from
the main PSB channels to other channels:
a) the proportion of children’s viewing devoted to the main PSB channels declined
steadily from 51.1% in 2005 to 36.0% in 2009 (Figure 4);
b) a higher proportion of children’s time was spent viewing commercial non-PSB
channels; their share of children’s viewing grew from 42.5% to 54.0% (Figure 3);
c) commercial PSB portfolio channels increased their share of the child audience
from 3.1% to 9.8% (Figure 4); and
d) children’s channels (both commercial and non-commercial) accounted for 29.7%
of viewing in 2009, up from 22.8% in 2005 (Figure 4).
Figure 4: Split in children’s viewing by channel groups
Proportion of viewing, %
Total weekly viewing by channel groups: Children 4-15
17.2
16.8
15.8
15.4
15.6
16.2
16.0
16.0%
17.5%
19.0%
21.3%
19.8%
20.0%
20.1%
3.3%
1.6%
3.7%
1.9%
3.2%
3.1%
3.0%
4.6%
2.8%
6.1%
2.2%
8.5%
2.4%
9.8%
24.3%
26.8%
29.1%
29.7%
17.5%
21.1%
0.5%
0.5%
22.8%
0.8%
1.1%
1.5%
1.6%
61.2%
55.3%
51.1%
45.8%
43.1%
38.6%
Av. weekly hours of TV viewing
All other non-PSB
channels
Music channels
Commercial PSB portfolio
channels (excl. dedicated
channels)
Children's channels
2.0%
36.0%
BBC portfolio channels
(excl. children's channels)
Main PSB channels
(BBC1, BBC2, ITV1, C4,
Five)
2003
2004
2005
2006
2007
2008
2009
Source: BARB
Note: Minor variations due to rounding
4 Music added to the ‘Commercial PSB portfolio channels’ measure in 2008 – The Hits removed from ‘Music Channels’ in 2008
29
Children’s viewing split by children’s and adult airtime
4.9
20
As Figure 5 demonstrates, the overall viewing split between children’s and adult
airtime remained fairly constant between 2005 and 2009. However, within these two
categories there have been a number of significant developments over time.
HFSS advertising restrictions – final review
Figure 5: Split in children’s viewing by type of airtime: Children’s vs. adult airtime
Total weekly viewing by airtime: Children 4-15
17.2
16.8
15.8
15.4
15.6
16.2
16.0
Av. weekly hours of TV viewing
Proportion of viewing, %
Commercial 'adult'
airtime
47.2%
49.6%
51.1%
53.1%
50.7%
51.4%
52.2%
BBC 'adult' airtime
23.3%
19.6%
17.8%
17.0%
29.5%
30.8%
31.1%
2003
2004
2005
17.3%
15.7%
14.9%
29.9%
31.9%
33.0%
32.9%
2006
2007
2008
2009
Total children's airtime
(slots on commercial
PSBs + children's
channels)
Source: BARB
Note: Minor variations due to rounding
‘Commercial adult airtime’ includes all non-BBC channels
33
Viewing during children’s airtime
4.10
Figure 5 shows that the overall proportion of viewing time spent in children’s airtime39
has remained fairly stable, increasing marginally from 31.1% in 2005 to 32.9% in
2009. This is despite the increase in children’s viewing to children’s channels (see
Figure 4).
4.11
Figures 6 shows that within children’s airtime 4-15 year olds viewing has shifted
away from the remaining children’s programming on the main PSB channels (9.5% in
2009 down from 26.7% in 2005) as the choice of dedicated children’s channels
available has increased and grown in popularity and the volume of children’s
programming on the main PSBs has declined. For example, the CITV strand that
used to appear in ITV1’s weekday afternoon schedules has been replaced by adult
programming.
Figure 6: Split in children’s viewing during children’s airtime
Proportion of viewing, %
Total weekly viewing during children’s airtime: Children 4-15
5.1
5.2
4.9
4.6
2.6%
8.4%
2.6%
9.2%
2.5%
11.6%
15.0%
5.0
5.3
5.3
17.9%
19.6%
22.0%
Av. weekly hours of TV viewing
during children’s airtime
Trouble
Disney channels
36.0%
41.1%
41.3%
44.9%
42.6%
44.7%
44.0%
15.3%
12.5%
10.5%
15.4%
18.0%
Commercial PSB channels
6.5%
4.5%
21.2%
23.4%
12.5%
25.3%
2003
19.2%
2004
16.2%
2005
Commercial non-PSB
channels (incl Disney XD)
3.7%
3.5%
24.2%
24.5%
BBC portfolio channels
(CBBC & Cbeebies)
BBC One & BBC Two
12.4%
11.5%
7.8%
6.0%
2006
2007
2008
2009
Source: BARB
Note: Minor variations due to rounding
39
slots on main PSBs or children’s channels
21
HFSS advertising restrictions – final review
4.12
In 2009, younger children (4-9 year olds) watched slightly more television during
children’s airtime than in 2005 (up from 42.7% of their viewing to 45.6%). There has
been little change for 10-15 year olds who spent 20.6% of their viewing in children’s
airtime in 2005, compared with 20.2% in 2009 (Figure 7).
4.13
Similarly, the growth in viewing to children’s channels was driven by 4-9 year olds,
accounting for 41.5% of their viewing in 2009 up from 31.8% in 2005. In contrast
children’s channels accounted for just 18.1% of 10-15 year olds viewing in 2009 up
from 14.6% in 2005 (Figure 7).
Figure 7: Overall split in children’s viewing: Children aged 4-9 and 10-15
Total weekly viewing: Children 4-9
15.6
16.5
Total weekly viewing: Children 10-15
15.9
Av. weekly hours of TV viewing
15.6
Adult: Commercial non-PSB
20.6%
25.4%
Adult: Commercial PSB channels
29.5%
39.2%
Children's: Trouble
0.6%
1.5%
14.6%
11.3%
0.3%
3.9%
8.3%
4.5%
8.8%
6.3%
2005
Source: BARB
Note: Minor variations due to rounding
21.2%
1.9%
11.9%
2.2%
Children’s airtime: 45.6%
18.7%
Children's: Disney channels
2009
Children's: Commercial non-PSB
(inc Disney XD)
Children's: Commercial PSB
channels
Children's: BBC portfolio (CBBC &
CBeebies)
Children's: BBC One & BBC Two
29.8%
23.6%
1.0%
2.5%
19.2%
1.2%
3.3%
7.5%
2.1%
2.6%
3.8%
2005
14.5%
6.1%
7.8%
0.3%
4.3%
1.7%
Children’s airtime:
20.2%
Adult: BBC One & BBC Two
Children’s airtime:
20.6%
16.2%
Proportion of viewing, %
21.5%
Children’s airtime: 42.7%
Proportion of viewing, %
Adult: BBC portfolio
2009
Viewing during adult airtime
4.14
Adult airtime (including in non-commercial channels) accounted for 67.2% of
children’s viewing in 2009. For 4-9 year olds the figure was lower at 54.4% and
higher for 10-15 year olds at 79.8%.
4.15
Over the same period, commercial adult airtime accounted for 52.2% of children’s
viewing, up marginally from 51.1% in 2005. As with children’s airtime there has been
a move away from viewing on the main commercial PSB channels to commercial
non-PSB channels. The growth in viewing to commercial non-PSB airtime has been
more pronounced among 10-15 year olds (Figure 7) up from 29.5% in 2005 to 39.2%
in 2009. For 4-9 year olds the increase was smaller, up from 20.6% in 2005 to 25.4%
in 2009.
4.16
Within adult airtime there was significant growth in the proportion of children’s
viewing represented by the commercial PSB portfolio channels, up from 3.1% in
2005 to 9.8% in 2009 (Figure 4) . These channels accounted for a higher share of
older children’s viewing (up from 3.8% in 2005 to 12.6% in 2009). For 4-9 year olds,
commercial PSB portfolio channels accounted for 7.0% of viewing in 2009, compared
with 2.4% in 2005.
22
HFSS advertising restrictions – final review
4.17
Overall, children’s viewing of commercial PSB portfolio channels went up by one
hour from 0.5 hours per week in 2005 to 1.6 hours in 2009 (Figure 8). For 10-15 year
olds the increase was 1.4 hours (up from 0.6 hours to 2 hours). For 4-9 year olds the
increase was 0.8 hours (up from 0.4 hours to 1.2 hours).
4.18
ITV2 and E4 remain the two most popular commercial PSB portfolio channels
amongst children but these channels have seen their share of children’s viewing
decline as more channels have launched and grown in popularity.
Figure 8: Split in children’s viewing to commercial PSB portfolio channels
Total weekly viewing to commercial PSB portfolio channels (excl. children’s channels): Children 4-15
0.3
0.3
Proportion of viewing, %
5.1%
39.7%
0.5
0.7
1.7%
10.0%
5.6%
2.1%
6.1%
6.3%
8.6%
40.1%
38.8%
1.0
4.9%
7.4%
2.8%
7.1%
5.6%
6.2%
6.2%
35.4%
Av. weekly hours of TV viewing to
commercial PSB portfoliochannels
1.4
1.6
5.9%
4.0%
7.9%
6.5%
3.8%
7.1%
Other
8.1%
7.9%
4Music
6.6%
5.7%
6.4%
4.5%
7.7%
4.7%
7.5%
5.0%
Five US
25.8%
23.7%
53.0%
Ch4+1
Fiver
29.8%
53.4%
Film 4
ITV4
More 4
45.0%
ITV3
34.2%
30.0%
25.1%
26.0%
E4
ITV2
2003
2004
2005
2006
2007
2008
2009
Source: BARB
Note: Analysis includes +1 channels
Minor variations due to rounding
4 Music added to the ‘Commercial PSB portfolio channels’ measure in 2008 – The Hits removed from ‘Music Channels’ in 2008
Viewing across the day
4.19
Figure 9 suggests that children’s viewing during adult airtime in the pre-watershed
peak time slot (18:00-21:00) and post-21:00 has remained fairly consistent over time.
This suggests that although children now have access to a wider range of television
services, the overall distribution of viewing across the day has remained relatively
unchanged.
23
HFSS advertising restrictions – final review
Figure 9: Split in children’s viewing by daypart
Proportion of viewing, %
Total weekly viewing by daypart: Children 4-15
17.2
16.8
15.8
15.4
5.8%
7.7%
6.0%
8.2%
5.7%
8.3%
16.9%
17.7%
19.0%
16.5%
17.5%
17.8%
Av. weekly hours of TV viewing
15.6
16.2
16.0
5.9%
8.1%
5.5%
7.9%
5.4%
7.7%
5.4%
8.1%
Adult airtime: Commercial
2230+
19.2%
18.7%
18.8%
19.0%
Adult airtime: Commercial
2100-2229
19.6%
18.4%
19.2%
19.5%
Adult airtime: Commercial
1800-2059
Adult airtime: Commercial pre
1759
23.3%
19.6%
17.8%
17.0%
17.3%
15.7%
14.9%
Adult airtime: Total BBC
29.5%
30.8%
31.1%
29.9%
31.9%
33.0%
32.9%
2003
2004
2005
2006
2007
2008
2009
Total children's airtime (slots
on main PSBs + children's
channels)
Source: BARB
Note: Minor variations due to rounding
‘Commercial adult airtime’ includes all non-BBC channels
34
Changes in food and drink advertising activity
Changes in food and drink advertising expenditure across media
4.20
The data below (Figures 10 and 11) show trends in all food and drink advertising
expenditure40 across traditional media (television, radio, press, outdoor and cinema).
This is a useful measure to compare activity across media and can provide an
indication of areas where advertising activity is increasing and declining. However
caution should be exercised in interpreting advertising spend data. Some of the
trends observed may result from changing advertising costs rather than a change in
the amount of advertising activity taking place.
4.21
As in the interim review, the data suggests that following a peak in 2007, total food
and drink advertising expenditure across all media fell to £863m in 2009. Advertising
spend on television declined to a low of £527m in 2009, while spend on press,
outdoor and cinema advertising increased between 2005 and 2009.
40
Data on HFSS food and drink expenditure is not available.
24
HFSS advertising restrictions – final review
Advertising spend by medium, £m
Figure 10: Food and drink advertising expenditure by medium
TV
590
584
548
23
94
569
582
527
Radio
553
Press
38
29
148
176
32
113
29
169
31
23
164
Outdoor
176
Cinema
79
15
81
15
83
18
77
16
2003
2004
2005
2006
100
24
83
27
2007
2008
2009
103
30
Source: Nielsen Media
Note: Minor variations due to rounding
4.22
Figure 11 shows that the proportion of total food and drink advertising spend
represented by television fell from 67.1% in 2005 to 61.0% 2009. Over the same
period, the proportion of spend allocated to press advertising increased from 17.0%
to 20.4%.
Share of spend by medium, %
Figure 11: Share of expenditure on food and drink advertising by medium
TV
72.2%
69.7%
67.1%
65.7%
64.5%
66.2%
61.0%
Radio
Press
3.1%
12.4%
4.0%
14.2%
4.4%
3.3%
17.0%
20.3%
3.6%
3.2%
2.7%
18.5%
18.7%
Outdoor
20.4%
Cinema
10.4%
10.3%
1.9%
2003
1.9%
9.5%
2.1%
8.9%
1.9%
2004
2005
2006
11.2%
9.4%
11.6%
2.7%
3.0%
3.4%
2007
2008
2009
Source: Nielsen Media
Note: Minor variations due to rounding
25
HFSS advertising restrictions – final review
4.23
Advertising spend on food and drink products across the internet increased from
£1.9m in 2005 to £8.7m in 2009 – a rise of 353%, as compared to a 39% increase in
expenditure on internet advertising for all product categories.
Changes in the volume of food and drink advertising on television
4.24
The analysis below covers the amount of both food and drink advertising and HFSS
advertising shown on television between 2005 and 2009, and is based on the
assessment of television advertising spots.
4.25
This data indicates the amount of advertising shown, where it is being broadcast and
at what time of day. It is not a measure of exposure to advertising, which is measured
in impacts (see Section 5).
4.26
Figure 12 shows that between 2005 and 2009:
a) there was an 88% increase in the total number of television advertising spots
across all product categories on television (from 17.4m to 32.7m). These
increases can be attributed in large part to the proliferation of advertising-funded
channels over this period;
b) the absolute number of adverts for all food and drink advertising rose 115% (from
2.2m to 4.8m) and by 85% (from 1.7m to 3.2m) for HFSS advertising; and
c) as a proportion of all advertising, food and drink advertising increased its share
from 12.9% in 2005 to 14.7% in 2009. By contrast, the share of advertising
attributable to HFSS products hardly changed (at 9.8%, down fractionally from
10.0%), suggesting that the growth in food and drink advertising came from nonHFSS products.
Figure 12: Total television advertising spots food and drink and HFSS: 2005 vs. 2009
Total television advertising spots
Spots
Share of spots
32.7m
32.7m
17.4m
17.4m
1.7
2.2
29.5
27.9
10.0%
9.8%
All other
categories (incl.
Other Food&
Drink)
87.1%
85.3%
90.0%
90.2%
2009
2005
Food & Drink
All other
categories (Motor,
retail, etc)
15.6
15.1
2005
14.7%
HFSS*
Share of spots, %
Spots (m)
17.4m
12.9%
3.2
4.8
2009
2005
2009
2005
2009
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
4.27
26
The remaining spot data in this section deals exclusively with HFSS spots, as this
provides more insight into the effects of the restrictions on children’s exposure to
HFSS advertising restrictions – final review
HFSS advertising than data for all food and drink spots. However in order to provide
trend data consistent with previous publications, additional figures on all food and
drink advertising spots can be found in Annex 5.
HFSS spots in adult vs children’s airtime
4.28
The data shows that:
a) by 2009, HFSS advertising spots had been eliminated from children’s airtime as a
result of the scheduling restrictions; and
b) between 2005 and 2009, the total number of HFSS spots in adult airtime rose by
124% from 1.4m to 3.2m. Most of this increase occurred on commercial non-PSB
channels (128%), while the number of HFSS spots in adult airtime on commercial
PSB channels grew by just 4%.
4.29
Some of the increase in HFSS spots on commercial non-PSB channels is likely to be
due to the proliferation of such channels since 200541. It is also possible that some
displacement of HFSS spots from children’s airtime to adult airtime has occurred.
However it is not possible to separate this out from the broader developments
described above.
Figure 13: HFSS spots by airtime
HFSS* spots by airtime
Spots
Share of spots
3.3m
1.7m
3.2
Share of spots, %
Spots (m)
Adult airtime –
Commercial nonPSB channels
Adult airtime Commercial PSB
channels
80.3%
98.7%
1.4
2.3%
0.04
0.29
2005 HFSS
Proxy
Children’s airtime
– Commercial
non-PSB
channels
Children’s airtime
- Commercial
PSB channels
17.0%
0.04
0.4%
1.3%
2009 HFSS
Proxy
2005 HFSS
Proxy
2009 HFSS
Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
63
HFSS spots by channel group
4.30
With the exception of children’s airtime on the main PSB channels and children’s
channels, the absolute volume of HFSS spots increased across all advertisingfunded channels. The proportion of HFSS advertising spots aired on advertisingfunded channels (other than music channels and commercial PSB portfolio channels)
increased from 57.0% in 2005 to 75.2% in 2009, and on commercial PSB portfolio
channels, from 4.0% to 8.2%.
41
Figure 2.11 Television channel licences issued Communications Market Report Ofcom August 2009 gives an
indication of the proliferation of channels between 2005 and 2009
27
HFSS advertising restrictions – final review
Figure 14: HFSS spots by channel groups
HFSS* spots by channel groups
Spots
Share of spots
3.2m
All other
commercial nonPSB channels
Music channels
57.0%
75.2%
Share of spots, %
Spots (m)
2.4
1.7m
1.0
19.4%
0.3
0.1
0.04
0.5
0.29
0.3
0.04
2009 HFSS Proxy
2005 HFSS Proxy
4.0%
2.3%
15.3%
PSB portfolio
channels
Adult airtime Commercial PSB
channels
Children’s airtime
– Commercial nonPSB channels
Children’s airtime Commercial PSB
channels
17.0%
0.4%
8.2%
1.3%
2005 HFSS Proxy
2009 HFSS Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
66
HFSS spots by day part
4.31
An increase in the absolute number of HFSS advertisements is visible across all day
parts, particularly the 12:30-15:15 and the post-21:00 slots. Due to the restrictions on
children’s airtime, all of the additional spots have appeared in adult airtime. This
growth can in large part be attributed to the overall increase in advertising resulting
from the growth in the number of commercial channels, but may also be the result of
more HFSS advertising on existing channels. Another factor may be a shift in
advertising spots from children’s airtime to adult airtime. The proportion of spots
transmitted after 18:00 increased from 56.7% in 2005 to 61.8% in 2009. This
increase can also be attributed to the factors listed above.
Figure 15: HFSS spots by day part
HFSS* spots by daypart
Spots
Share of spots
25.8%
3.2m
31.4%
22:30-close
8.8%
1.7m
0.4
0.4
0.6
0.2
0.3
0.1
0.1
0.1
0.1
0.1
0.3
0.1
0.2
2005 HFSS Proxy
Share of spots %
Spots(m)
1.0
0.3
0.3
0.3
0.0
2009 HFSS Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
28
21:00-22:30
10.9%
16.4%
18:00-21:00
17:00-18:00
3.7%
5.1%
19.5%
7.4%
12:30-15:15
7.1%
4.5%
6.0%
8.2%
9.8%
06:00-09:30
9.2%
Children's airtime
17.4%
8.8%
2005 HFSS Proxy
2009 HFSS Proxy
15:15-17:00
09:30-12:30
HFSS advertising restrictions – final review
4.32
Changes in the volume of HFSS advertising spots do not in themselves shed much
light on how much HFSS advertising children are seeing. Spots, viewing and
exposure data need to be assessed together to understand fully the effects of any
changes that may have occurred. This analysis can be found in Section 5.
29
HFSS advertising restrictions – final review
Section 5
5 Changes in the amount of HFSS
advertising seen by children
Introduction
5.1
The scheduling restrictions for HFSS advertising introduced in 2007 were intended to
secure a significant reduction in the amount of HFSS advertising seen by children up
to the age of 16. This section sets out the change in children’s exposure to this type
of advertising between 2005 (the base year used in our analysis) and 2009 (the first
year the restrictions were fully implemented); taking into account the changes to both
the advertising landscape and to children’s viewing habits (see Section 4).
Key findings
5.2
Overall children saw significantly less HFSS advertising in 2009 than in 2005. Their
exposure to HFSS advertising in children’s airtime has been ended, and has
remained stable across adult airtime overall.
5.3
Between 2005 and 2009:
a) children saw at least42 37% less HFSS advertising (i.e. a reduction of 4.4bn
impacts);
b) younger children (4-9 year olds) saw at least 52% less HFSS advertising (3.1bn
impacts) and older children (10-15 year olds) saw at least 22% less (1.4bn
impacts);
c) overall children saw 40% less HFSS advertising on the commercial PSB
channels (2.4bn impacts) and 33% less on commercial non-PSBs; (2.0bn
impacts);
d) during children’s airtime, exposure to HFSS advertising was eliminated on both
commercial PSBs (i.e. children’s slots such as Five’s Milkshake) and commercial
non-PSBs (i.e. children’s channels such as Nick Jr, Tiny POP) as a direct result
of the advertising restrictions;
e) children saw 28% (1.4bn impacts) less HFSS advertising during adult airtime on
the commercial PSB channels. However over the same period exposure to HFSS
advertising during adult airtime on commercial non-PSB channels rose 46%
(1.3bn impacts), offsetting most of the reductions from the commercial PSB
services. As a result children saw 1% (0.1bn impacts) less HFSS advertising
overall in adult airtime;
f)
42
the growth in HFSS impacts during adult airtime on commercial non-PSB
channels was driven by impacts on commercial PSB portfolio channels (up 237%
from 0.5bn to 1.8bn) which reflects children’s increased viewing to these services
over this period (see Section 4); and
See section 3.14- 3.19
30
HFSS advertising restrictions – final review
g) despite an increase in the volume of HFSS advertising aired throughout the day,
HFSS exposure fell in all day parts before 21:00 and by 25% between the peak
hours of 18:00-21:00. These reductions were driven by the decline in impacts
during children’s airtime. Looking exclusively at adult airtime it is possible to see
that HFSS exposure also dropped 11% during the peak viewing slot 18:00 21:00, but increased during most other day parts.
5.4
The data suggests that 43.8% (5.7bn) of all the food and drink advertising seen by
children in 2009 was for HFSS products likely to appeal to them43. The remaining
2.0bn HFSS impacts were assessed as being for products only likely to appeal to
adults.
5.5
Ofcom has found very few instances of broadcasters breaking the rules by inserting
HFSS commercial messages in children’s airtime – whether in the form of
advertisements for HFSS products, sponsorship messages in the name of HFSS
products, or non-product advertising in the name of brands commonly associated
with HFSS products. Ofcom is therefore satisfied that, with very few exceptions,
broadcasters are complying with the letter and the spirit of the scheduling restrictions.
Overall changes in children’s exposure to HFSS advertising
5.6
In the February 2007 statement, Ofcom estimated that once fully implemented, the
effect of the advertising restrictions would be to reduce HFSS impacts for children
aged 4-15 by 41% of the 2005 level. The statement also estimated that HFSS
advertising seen by 4 - 9 year olds could decline by 51%.
5.7
As explained in Section 3, the best estimate of change since 2005 requires a
comparison of the 2005 HFSS proxy and the 2009 HFSS proxy. As a result the
outcome is necessarily approximate, and should not be taken as an exact indication.
Moreover, the results of this process are not directly comparable with the 41%
reduction estimate we made in February 2007, which was prepared on the basis of
the 2005 HFSS proxy, nor with the 2007/8 HFSS proxy developed for the interim
review.
43
See Annex 3 for appeal definitions
31
HFSS advertising restrictions – final review
All Airtime
Figure 16: Children’s exposure to HFSS advertising
All Food & Drink impacts: Children 4-15
Impacts
Share of Impacts
15.0bn
19.3%
2.9
13.0bn
Impacts (bn)
5.4
12.1
Share of impacts, %
41.1%
All other
Food &
Drink
HFSS
proxies
80.7%
58.9%
7.7
2005 data (2005 HFSS 2009 data (2009 HFSS
proxy)
Proxy)
2005 data (2005 HFSS 2009 data (2009 HFSS
proxy)
Proxy)
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
5.8
Overall, children’s exposure to HFSS advertising fell by 37% from 12.1bn impacts in
2005 to 7.7bn impacts in 2009. This was driven by the elimination of HFSS impacts
during children’s airtime (Figure 16).
5.9
Breaking this down by age group, the data shows that between 2005 and 2009:
a) HFSS impacts dropped 52% among 4-9 year olds (down from 5.9bn to 2.8bn).
The reduction was driven by the removal of all HFSS advertising from children’s
airtime where younger children spend 45.6% of their viewing time (Figure 18);
b) 10-15 year olds HFSS impacts fell 22% (down from 6.2bn to 4.8bn impacts). This
smaller reduction reflects older children’s tendency to spend just 20.2% of their
viewing time in children’s airtime (Figure 19);
c) HFSS child impacts dropped by 40% (down from 6.0bn to 3.6bn) on the
commercial PSBs channels between 2005 and 2009. The figure was higher for 49 year olds (47%, down 1.2bn impacts) and lower for 10-15 year olds (35%, down
1.2bn impacts) who spend a greater proportion of their time watching these
predominantly adult content based channels;
d) on commercial non-PSB channels. there was a 33% fall overall in HFSS
exposure during the same period (down from 6.1bn to 4.1bn impacts); and
e) the reduction was higher for younger children at 56% (1.8bn impacts) due to their
propensity to view children’s channels and lower for older children at 7% (0.2bn
impacts) who view more adult airtime.
32
HFSS advertising restrictions – final review
Figure 17: HFSS impacts by airtime
HFSS* impacts by airtime: Children 4-15
Impacts
Share of impacts
22.9%
12.1bn
Adult airtime –
Commercial nonPSB channels
52.8%
Share of impacts, %
Impacts (bn)
2.8
7.7bn
5.0
4.1
Adult airtime Commercial PSB
channels
41.2%
47.0%
27.4%
3.3
3.6
8.4%
1.0
2005 HFSS
Proxy
Children’s airtime
– Commercial
non-PSB
channels
Children’s airtime
- Commercial
PSB channels
2009 HFSS
Proxy
2005 HFSS
Proxy
2009 HFSS
Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
HFSS impacts in children’s airtime vs. adult airtime
Children’s airtime
5.10
HFSS impacts in children’s airtime were eliminated for both age groups as a result of
the advertising restrictions. However children’s airtime accounted for just 24.3% of all
10-15 year old HFSS impacts back in 2005, compared with almost half (48.0%) for 49 year olds. This difference is due to younger children spending a much greater
proportion of their viewing in children’s airtime than 10-15 year olds (see Fig 7) and
explains why the decline in exposure during children’s airtime has had a more
pronounced effect on the overall exposure of 4-9 year olds than 10-15 year olds.
Figure 18: HFSS impacts for children aged 4-9: adult vs children’s airtime
HFSS* impacts by airtime: Children 4-9
Impacts
Share of impacts
18.3%
5.9bn
50.3%
2.0
2.8bn
1.4
Share of impacts, %
Impacts (bn)
1.1
Adult airtime Commercial nonPSB channels
Adult airtime Commercial PSB
channels
33.6%
Children’s airtime
- Commercial nonPSB channels
37.0%
2.2
49.4%
Children’s airtime
- Commercial
PSB channels
1.4
11.0%
0.6
2005 HFSS
Proxy
2009 HFSS
Proxy
2005 HFSS
Proxy
2009 HFSS
Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
33
HFSS advertising restrictions – final review
Figure 19: HFSS impacts for children aged 10-15: adult vs children’s airtime
HFSS* impacts by airtime: Children 10-15
Impacts
Share of impacts
6.2bn
Adult airtime –
Commercial nonPSB channels
27.2%
1.7
54.3%
2.6
3.0
Share of impacts, %
Impacts (bn)
4.8bn
Adult airtime Commercial PSB
channels
48.4%
45.6%
1.1
2.2
18.3%
2009 HFSS
Proxy
2005 HFSS
Proxy
6.0%
0.4
2005 HFSS
Proxy
Children’s airtime
– Commercial
non-PSB
channels
Children’s airtime
- Commercial
PSB channels
2009 HFSS
Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
57
Adult airtime
5.11
Between 2005 and 2009 HFSS impacts fell 28% (1.4bn impacts) during adult airtime
on the commercial PSBs channels (from 5.0bn to 3.6bn) as children’s viewing
migrated to commercial non-PSB channels (Figure 17). The decline was similar for
all age groups (-29% and -27% for 4-9 year olds and 10-15 year olds respectively).
5.12
This reduction was offset by a corresponding increase in exposure to HFSS
advertising during adult airtime on commercial non-PSB channels. Overall, children
saw 46% (1.3bn impacts) more HFSS advertising on these services (up from 2.8bn
to 4.1bn), with 4-9 year olds viewing 32% (0.3bn impacts) more and 10-15 year olds
seeing 55% (0.9bn impacts) more. As Figure 7 in Section 4 shows, non-PSB
channels account for a greater proportion of older children’s viewing.
5.13
The shift in viewing and exposure from commercial PSB channels to commercial
non-PSB channels has resulted in an overall 1% (0.1bn) net reduction in HFSS child
impacts across all adult airtime. For 4-9 year olds the overall reduction in HFSS
impacts during adult airtime was 8% (0.2bn) but there was a 3% (0.1bn impacts)
increase in HFSS exposure for 10-15 year olds.
5.14
Within commercial non-PSB adult airtime there was significant growth in children’s
exposure to HFSS advertising on commercial PSB portfolio channels with a 237%
(1.3bn impacts ) increase in HFSS impacts, albeit from a low base (0.5bn in 2005 to
1.8bn in 2009). For 4-9 year olds, the increase was 221% (0.4bn impacts) and for 1015 year olds it was 246% (0.8bn impacts). This growth can in part be explained by
the increase in the number of PSB portfolio channels available across the
multichannel platforms44, the growth in HFSS advertising spots on this group of
channels, and importantly the increase in viewing to these services as illustrated in
Section 4.
44
Figure 4.2 page 18 Changes in the nature and balance of television food advertising to children 17 December
2008. See web link on page 2
34
HFSS advertising restrictions – final review
5.15
When the adult airtime HFSS impacts delivered by the main PSBs and their portfolio
channels are combined, the data suggests that the total number of HFSS impacts for
these channel groups as a whole fell marginally (by 2% from 5.5bn in 2005 to 5.4bn
in 2009). This indicates some displacement of HFSS impacts away from the main
PSBs to their portfolio channels. This hypothesis is also supported by the evidence of
the changes in children’s viewing habits.
Figure 20: Children’s exposure to HFSS advertising by channel groups
HFSS* impacts by channel groups: Children 4-15
Share of impacts
Impacts
16.1%
12.1bn
25.6%
2.4%
4.4%
2.0
7.7bn
2.0
0.3
1.8
Share of impacts, %
Impacts (bn)
Music channels
3.9%
0.3
0.5
5.0
41.2%
23.3%
47.0%
8.4%
2009 HFSS Proxy
2005 HFSS Proxy
Children’s airtime –
Commercial non-PSB
channels
Children’s airtime Commercial PSB
channels
3.6
1.0
Commercial PSB
portfolio channels
Adult airtime Commercial PSB
channels
27.4%
3.3
2005 HFSS Proxy
All other non-PSB
channels
2009 HFSS Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
54
5.16
Considering children’s viewing, HFSS advertising spot data and HFSS impacts in the
round also suggests that children’s exposure to HFSS advertising during adult airtime
is, in large part, driven by viewing trends. Between 2005 and 2009:
a) HFSS spots during adult airtime on commercial PSB channels rose by 4% (1,000
spots), however child impacts on these channels fell 28% (1.4bn), as children’s
viewing of these channels declined by 21%;
b) spots also increased on PSB portfolio channels, by 285% (0.2m), but over the
same period children’s viewing to these services increased by 222% and impacts
increased 237%;
c) all other commercial non-PSB channels (excluding PSB portfolio channels and
music channels) accounted for 75.2% of all HFSS spots in 2009, but only 25.6%
of child HFSS impacts. This disparity between the proportion of spots and the
share of impacts represented by these channel groups can be explained by the
differences in viewing to these channels (see Section 4). While a large number of
spots are aired across the numerous other commercial non-PSB channels,
relatively more impacts are delivered on channels which are more popular
amongst children.
35
HFSS advertising restrictions – final review
Figure 21: HFSS impacts by channel groups – Children 4-9 and 10-15
HFSS* impacts by channel groups
Impacts
Share of impacts
Children 4-9
Children 10-15
Children 4-9
13.6%
6.2bn
0.8
1.1
0.1
0.2
0.2
0.3
4.8bn
1.2
2.0
0.2
2.8bn
2.2
1.2
0.7
0.1
0.6
1.4
0.6
2005 HFSS
Proxy
3.0
25.8%
3.3%
5.5%
Music channels
33.6%
21.7%
24.3%
48.4%
49.4%
1.1
2.2
2005 HFSS
Proxy
2009 HFSS
Proxy
45.6%
6.0%
Commercial PSB
portfolio channels
Adult airtime Commercial PSB
channels
18.3%
11.0%
All other commercial
non-PSB channels
4.3%
37.0%
0.4
2009 HFSS
Proxy
18.5%
25.3%
3.3%
Share of impacts, %
5.9bn
Impacts (bn)
1.5%
3.3%
Children 10-15
Children’s airtime –
Commercial NonPSB channels
Children’s airtime Commercial PSB
channels
0.0%
2005 HFSS Proxy 2009 HFSS Proxy 2005 HFSS Proxy 2009 HFSS Proxy
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
Advertising seen by children by time of day
Overall trends across the day for all airtime
5.17
Figure 22 below shows that children’s exposure to HFSS advertising declined in all
day parts before 21:00 despite the increase in HFSS spots throughout the day. This
46% (4.6bn impacts) reduction was driven by the elimination of HFSS impacts during
children’s airtime.
5.18
The largest reduction in HFSS exposure occurred during the 06:00-09:30 slot (84%
or 1.5bn impacts). There was also a 25% (1.0bn impact) drop in child HFSS impacts
during the peak time 18:00-21:00 slot; and
5.19
The absolute number of HFSS impacts delivered after 18:00 fell by 14% (0.9bn
impacts) between 2005 and 2009 (down from 6.3bn in 2005 to 5.4bn in 2009), driven
by the decline in impacts during the 18:00–21:00 slot. As much of the impact
reduction occurred in children’s airtime the share of impacts represented by these
evening slots (after 18:00) increased from 51.9% in 2005 to 70.6% in 2009.
36
179
HFSS advertising restrictions – final review
Figure 22: HFSS impacts by day part: All airtime
HFSS* impacts by daypart: Children 4-15, All airtime
Impacts
Share of impacts
6.1%
12.1bn
0.7
10.5%
12.1%
20.2%
1.5
22:30-close
4.1
7.7bn
0.8
1.5
1.0
1.2
0.7
1.2
1.8
2005
3.1
Share of impacts, %
Impacts (bn)
21:00-22:30
33.7%
18:00-21:00
39.9%
17:00-18:00
8.1%
15:15-17:00
9.9%
12:30-15:15
5.9%
9.8%
0.6
0.4
0.5
0.5
0.3
14.5%
2009
2005
8.3%
09:30-12:30
5.0%
06:00-09:30
6.2%
6.2%
3.8%
2009
Source: Nielsen Media
Note: Minor variations due to rounding
*HFSS refers to proxy measures
Analysis excludes McDonald’s film numbers certified as non-HFSS
Adult airtime
5.20
Between 2005 and 2009, HFSS impacts fell 48% (0.3bn) during the 06:00–09:30 slot
and 11% (0.4bn) during the 18:00-21:00 slots in adult airtime overall but rose during
all other adult day parts.
5.21
During adult airtime on the commercial PSBs:
a) HFSS impacts fell in all day parts for children aged 4-15;
b) between 17:00 and 18:00 HFSS impacts fell by 8% (0.03bn impacts) for children
overall. The reduction was 18% (0.04bn impacts) for children aged 4-9 but there
was a 2% (3m impacts) increase in HFSS impacts for older children;
c) HFSS impacts between 18:00 and 21:00 dropped 28% for all children from 2.3bn
to 1.7bn. The reduction was 30% (0.3bn) for children aged 4-9 and 27% (0.4bn)
for those aged 10-15;
d) during the late evening slot 21:00-22:30 there was a 25% decline in HFSS
impacts for children overall (from 1.0bn to 0.7bn impacts). For 4-9 year olds the
reduction was 19% (0.06bn impacts); for 10-15 year olds, -27% (0.2bn); and
e) while the number of HFSS advertising spots declined by 10% between 18:00 and
21:00, there were increases of 15% in the 17:00-1800 slot and 2% in the 21:00–
22:30 slots. The fall in HFSS impacts across all three sections of the schedule
suggests that the reduction results mainly from children watching fewer
programmes on these channels during these times.
5.22
During adult airtime on the commercial non-PSBs:
37
HFSS advertising restrictions – final review
a) HFSS impacts increased in all day parts in adult airtime, with the exception of the
06:00 – 09:30 slot;
b) HFSS impacts between 17:00 and 18:00.increased by 46% (by 0.1bn from 0.2bn
to 0.3bn) for children overall. The growth was 33% (0.02bn) for younger children
and 54% (0.06bn) for older children;
c) between 18:00-21:00 HFSS impacts rose by 26% (up from 1.1bn to 1.4bn) for all
children, 22% (0.1bn) for 4-9 year olds and 28% (0.2bn) for 10-15 year olds; and
d) the 21:00-22:30 slot saw a 107% increase in impacts for children overall (from
0.4bn to 0.8bn). For younger children HFSS impacts grew by 105% (0.1bn), for
older children it was 108% (0.3bn).
5.23
HFSS spots on the commercial non-PSBs during adult airtime increased by 128%
(around 0.08m spots), between 17:00 and 18:00, and 124% (0.3m spots) between
18:00 and 21:00 and 134% (0.2m spots) between 21:00 and 22:00. In contrast
children’s exposure grew at a much slower rate, suggesting that much of this
advertising may not be targeted at children. The increase in HFSS exposure across
all day parts on commercial non-PSBs can be attributed to both the growth in spots
and increased viewing to these channels.
HFSS advertising for products of appeal to children
5.24
Not all food and drink advertising, whether for HFSS or non-HFSS products, is likely
to appeal to children – examples include advertisements for cooking oils, beverages
such as tea or coffee, and meal ingredients such as meat or fish. Given that such
advertising is unlikely to have a significant effect on children’s food preferences, it is
important to understand how much food and drink advertising falls into this category.
5.25
As described in Section 3, Ofcom classified food and drink ‘brands’ advertised in
2009 into two categories, HFSS and non-HFSS. To determine appeal, it was then
necessary to assess whether each of the ‘brands’ within these two groups was likely
to be attractive to all audiences, including children, or whether it would only appeal to
adults. For example we assessed Flora Proactive spread to be of appeal to adults,
but Cadbury Wispa to be of appeal to both adults and children 45. Ofcom estimated
that, of the 13.0bn food and drink child impacts delivered in 2009, 7.7bn were for
HFSS products, equivalent to 58.9% of all food and drink impacts. Analysis of the
appeal of products (Figure 23) suggests that 43.8% (5.7bn) of food and drink
advertising was for HFSS products of appeal to both children and adults. The
remaining 2.0bn HFSS impacts were assessed as being impacts for products only
likely to appeal to adults. Given that the majority of food and drink impacts were
delivered during adult airtime, similar patterns are observed across the commercial
PSB and commercial non-PSB channels.
45
See Annex 4 for full product lists by appeal
38
HFSS advertising restrictions – final review
Figure 23: Breakdown of food and drink impacts by nature of appeal, 2009:
Breakdown of food and drink impacts by nature of appeal: Children 4-15
Impacts
Share of impacts
13.0bn
15.4%
22.2%
23.3%
22.9%
2.9
Non-HFSS appeal to adults
2.5
2.0
6.2bn
5.4bn
1.3
5.7
0.6
0.9
2.7
Total airtime
Share of impacts, %
Impacts (bn)
18.9%
1.4
10.3%
11.5%
17.2%
16.5%
Non-HFSS appeal to all
15.1%
83.9%
HFSS - appeal
to adults
0.7
1.0
49.1%
43.8%
3.0
49.1%
1.4bn
0.2
1.2
'Adult' airtime 'Adult' airtime - Children's airtime
Commercial PSBs Commercial nonPSBs
HFSS - appeal
to all
Total airtime
'Adult' airtime Commercial
PSBs
'Adult' airtime Commercial
non-PSBs
Children's
airtime
Source: Nielsen Media
Note: Minor variations due to rounding
5.26
83.9% (1.2bn impacts) of the food and drink advertising seen by children during
children’s airtime was for non-HFSS products likely to appeal to them. The remaining
advertisements were for non-HFSS adverts of appeal to adults, such as tea, soya
milk and lean steak mince.
Compliance with scheduling restrictions
5.27
Ofcom is aware of only two instances where an HFSS advertisement was mistakenly
aired during children’s airtime, the first of which occurred soon after the restrictions
came into force and was reported in the interim review. Ofcom is therefore satisfied
that broadcasters are, with very few exceptions, complying with the scheduling
restrictions for spot advertising.
Brand advertising and sponsorship
5.28
The terms of reference for the review explain that, amongst other things, we would
look at whether advertisers are evading the spirit of the restrictions, by airing
advertising and sponsorship in the names of brands commonly associated with
HFSS products in children’s airtime.
Brand advertising
5.29
46
In the November 2006 statement and further consultation, we said that there would
be practical difficulties in restricting brand advertising – advertising that promotes a
brand rather than a specific product. In particular, we noted that, as brands were
often used for a range of both HFSS and non-HFSS products, it would be difficult to
conclude that a brand was wholly or mainly used for marketing HFSS products46. A
number of respondents called for restrictions, but none offered credible ways of
overcoming these practical difficulties. For this reason, and the fact that it was not
Paragraph 5.148 of the November 2006 document. See web link page 1.
39
HFSS advertising restrictions – final review
clear to what extent advertisers would seek to substitute brand for product
advertising, Ofcom concluded that we should not make brand advertising subject to
scheduling restrictions at that time. However, we said that we would keep the issue
under review.
5.30
In guidance produced for advertisers, Ofcom’s co-regulator, the Advertising
Standards Authority, makes clear that brand advertising which features products that
are identifiable as HFSS products, or uses brand names that are synonymous with
HFSS products are likely to be regarded as advertisements for HFSS products47.
5.31
In publishing our February 2007 statement, Ofcom noted that the Department of
Health would be collecting data on brand advertising that would be available for
Ofcom’s review48. However, as industry data does not separately distinguish
commercial messaging that is brand advertising from product advertising, this has
not proved possible. As a result, both are included within industry data on advertising
spots and impacts. Clearcast assesses all the advertisements submitted for
clearance, whether for products or brands, on the same basis. Given that children
are seeing less HFSS advertising overall (whether for products or brands), it is clear
that even if brand advertising has increased, it has not offset the overall decline in the
amount of HFSS advertising seen by children.
5.32
The interim review noted that anecdotal indications for the interim review indicated
there had not been an increase in the incidence of brand advertising49. That position
has not changed. Although we do not have the data to enable us to draw definitive
conclusions on the extent to which advertisers are using brand advertising, we are
not aware of evidence suggesting that advertisers are making widespread use of
brand advertising in order to circumvent the rules.
Sponsorship
5.33
Both the content and scheduling rules that apply to HFSS product advertising apply
equally to sponsorship closely associated with HFSS products50. When the rules
came into force, there were concerns that advertisers might use sponsorship in the
name of brands associated with HFSS products (but not featuring actual products) as
a means of circumventing the restrictions. Compliance with the rules as they affect
sponsorship is a matter for Ofcom. In considering possible breaches, we have regard
to the content rules adopted by BCAP.
5.34
Since the rules were put in place, Ofcom has dealt with two breaches of the
sponsorship rules:
a) in the first case, two Spanish-language children’s channels (Cartoon Network and
Boomerang Spain) operated by Turner Entertainment Networks International
Limited (“Turner”), were found to have accepted sponsorship in the name of food
products believed to be HFSS products. Following investigation by Ofcom, the
sponsorship was found to be in breach of Rule 4.2.1(b) of the BCAP Rules on the
47
Advertising Guidance Note No. 7: Differentiating HFSS product TV advertisements from product TV
advertisements
(http://www.asa.org.uk/asa/codes/tv_code/Guidance_Notes/Differentiating+HFSS+product+TV+Advertisements+f
rom+Brand+TV+Advertisements.htm)
48
Paragraph A1.59, February 2007 statement
49
Paragraph 6.35 Changes in the nature and balance of food advertising to children Ofcom Dec 2008. See web
link page2
50
Paragraph 1.12, February 2007 statement
40
HFSS advertising restrictions – final review
Scheduling of Television Advertisements. Turner said that it had accepted that a
breach had occurred, and instituted training for staff at its Spanish office51; and
b) in the second case, Sky One (operated by British Sky Broadcasting Ltd)
broadcast episodes of The Simpsons sponsored by Domino’s Pizzas. Sky argued
that this was not sponsorship for a product but sponsorship for a delivery service.
Following investigation, Ofcom concluded that this particular sponsorship
amounted to product sponsorship promoting HFSS foods in programmes of
particular appeal to children under the age of 16. The sponsorship was therefore
in breach of Rule 4.2.1(b) of the BCAP Rules on the Scheduling of Television
Advertisements and, accordingly, in breach of Rule 9.3 of the Broadcasting Code,
which relates to sponsorship52.
5.35
The first case was reported in the interim review, the second finding was published in
early 2009. No further cases have come to light since then.
5.36
Ofcom is encouraged that, notwithstanding the extensive use made by broadcasters
of sponsorship, only two cases have come to light of inappropriate HFSS
sponsorship of programmes for children or of particular appeal to children. Given the
high level of awareness about the rules amongst broadcasters and other interested
groups, Ofcom is satisfied that any significant HFSS sponsorships of children’s
programming would come to its attention, and would be dealt with in accordance with
its usual procedures53.
51
Ofcom Broadcast Bulletin, Ofcom, 7 December 2008
(http://stakeholders.ofcom.org.uk/binaries/enforcement/broadcast-bulletins/obb147/Issue147.pdf)
52
Ofcom Broadcast Bulletin, Ofcom, 23 February 2009
(http://stakeholders.ofcom.org.uk/enforcement/broadcast-bulletins/obb128/)
53
Ofcom procedures for the consideration of statutory sanctions in broadcasting or other licence-related cases,
Ofcom, 16 December 2009 (http://stakeholders.ofcom.org.uk/broadcasting/guidance/)
41
HFSS advertising restrictions – final review
Section 6
6 Changes in the food and drink advertising
techniques seen by children
Introduction
6.1
As in the interim review this section is designed to ascertain what changes there may
have been in the nature of food and drink advertising, and in particular:
a) whether the revised content rules are being implemented as intended; and
b) what changes there have been to the use of techniques in food and drink
advertising that may appeal to children.
6.2
As previously, the analysis is based on all food and drink advertising. It has proved
impracticable to obtain data on whether individual advertisements broadcast before
the HFSS advertising restrictions came into force were for HFSS products or not.
Accordingly, the analysis of children’s exposure to food and drink advertisements
featuring techniques considered to be of appeal to children includes advertisements
for both HFSS and non-HFSS products.
6.3
Unlike the interim review this analysis is not based on full year data but on Q1 data
for both 2005 and 200954. Inevitably, given the limited data period, there is a risk that
individual advertising campaigns could have a disproportionately large impact on
findings; similarly the findings are likely to reflect the seasonality of some food and
drink advertising. Therefore the figures should be regarded as a snapshot, rather
than as definitive evidence of trends.
Background
6.4
BCAP’s Television Advertising Standards Code (see extract at Annex 2) was
amended to restrict the use of the following techniques:
a) licensed characters (that is, characters originally devised for another purpose,
such as animated films or cartoons);
b) celebrities (such as footballers);
c) promotions (such as those offering free gifts or tokens); and
d) health claims.
6.5
It was decided not to restrict the use of brand equity characters (characters originally
devised for marketing purposes, such as those associated with some breakfast
cereals), or ‘other characters’ (e.g. animated talking trees, puppets etc). However, in
the light of concerns that advertisers might make more extensive use of these, we
looked at the extent to which they had been used in food and drink advertising both
in the interim and final reviews.
54
The Department of Health stopped commissioning the collection of this data at the end of the first quarter of
2009. To enable a like-for-like comparison, we have compared data for Q1 2009 with data for Q1 2005
42
HFSS advertising restrictions – final review
Key findings
6.6
Surveys carried out by the ASA between 2008 and 2010 show that broadcasters are
complying with the restrictions on advertising techniques that may be used in
advertising aimed at children for food and drink products. In its latest compliance
survey55 the ASA found that all food and drink advertisements shown on the 67
television services (including regional ITV services) that were monitored complied
fully with the HFSS rules.
6.7
By assessing the data on changes in the use of restricted techniques in food and
drink advertising considered to be of particular appeal to children it is possible to see
that between Q1 2005 and Q1 2009:
a) there was a reduction in the use of all the techniques analysed (with the
exception of celebrities) during children’s airtime. However there was an increase
in the use of all these techniques during adult airtime and an increase in the use
of these techniques overall (with the exception of licensed characters). Where
these techniques were used during children’s airtime, this was to promote nonHFSS products, which is permitted; and
b) overall, there was a reduction in children’s exposure to commercials featuring
licensed characters, brand equity characters, other characters and promotions.
However exposure to commercials featuring celebrities and health claims
increased between the two data periods. Children’s exposure to all the creative
techniques fell during children’s airtime but increased during adult airtime.
Content Rules
6.8
The BCAP content rules set out in Annex 2 came into force for new campaigns in
March 2007; any campaigns that were already on air or in planning were required to
comply with the new rules from 1 July 2007. Key elements of the content rules
include prohibitions in advertisements for HFSS products targeted at pre-school and
primary school children of the use of licensed characters and celebrities, health
claims, and promotional offers.
6.9
Compliance with these rules in relation to spot advertising is monitored by the ASA56.
It has conducted three surveys of food and drink advertising to assess whether or not
broadcasters are complying with the rules:
a) the first survey57, carried out in 2007 (a few months after the rules came into
force), found that two television advertisements that appeared had breached
BCAP’s rules on health and safety and misleadingness respectively. However,
none of the adverts breached BCAP’s restrictions on HFSS advertising;
b) similarly, the second survey58, carried out in 2008 found that none of the
television advertisements surveyed had breached the HFSS advertising
restrictions, although one television advertisement breached a general food and
drink rule, against encouraging poor dietary practice; and
55
Food and Soft Drink Advertising Survey 2009 ASA June 2010. See web link on page 4
Application of these rules to sponsorship is the responsibility of Ofcom
57
Food and Soft Drink Advertising Survey 2007 ASA Jan 2008. See web link on page11
58
Food and Soft Drink Advertising Survey 2008 ASA Nov 2008. See web link on page11
56
43
HFSS advertising restrictions – final review
c) finally, the third survey59, carried out in 2009, found once again that none of the
television advertisements surveyed had breached the HFSS advertising
restrictions. Two advertisements were found to have breached general food and
drink rules on misleadingness, evidence, and truthfulness.
6.10
Accordingly, Ofcom is satisfied that advertisers are complying with the HFSS content
rules set out in Annex 2.
Advertising techniques
6.11
In this final review, Ofcom has looked at what changes there have been in the use of
food and drink advertising techniques between Q1 2005 and Q1 2009. In particular,
we have looked at the use of those techniques regulated by BCAP’s code (see
extract at Annex 2) on the grounds that they are calculated to appeal to children. In
addition, we looked at the use of brand equity characters (that is, characters
originally devised for marketing purposes, such as those associated with particular
breakfast cereals); and ‘other characters’ (whether live or animated e.g. animated
talking trees, puppets etc) which are not restricted by the advertising code and
therefore could potentially be used in place of other techniques to appeal to children.
6.12
The analysis of changes in creative techniques is based on data for advertising for all
products within the Billetts Media food and drink categories, as defined in Annex 3.
However, it should be noted that the Billetts definition of food and drink categories
differs slightly from the food and drink definition used throughout the rest of the
document (which is based on Nielsen Media data), and therefore caution should be
exercised when comparing findings in this chapter with those elsewhere. These
categories are listed in Annex 3.
6.13
In this analysis, adverts are subject to multiple coding, to take account of adverts in
which more than one of the creative techniques is used. For example, in the case of
a popular cereal (such as Frosties) including an offer for children’s books, the advert
would be coded twice; once for the use of a brand equity character (Tony the Tiger)
and once for the use of promotions.
6.14
It should be noted that:
a) as explained in Section 4 the growth in the number of channels will tend to lead
to a growth in the number of advertising spots; and
b) advertising spot figures in this section have been rounded to the nearest
thousand.
6.15
A more detailed version of this analysis can be found in Annex 7.
Licensed characters
6.16
59
The volume of food and drink spots featuring a licensed character fell by 23%
between Q1 2005 and Q1 2009 (from 25,000 to 19,000). Licensed characters initially
accounted for 4.3% of all food and drink spots this fell to 1.7% in Q1 2009. While
there has been a 70% (17,000 spots) decline in food and drink spots featuring
licensed characters in children’s airtime, there has been a 1,869% (11,000 spots)
increase during adult airtime. Furthermore, adult airtime accounted for only 2.4%
Food and Soft Drink Advertising Survey 2009 ASA June 2010. See web link on page 4
44
HFSS advertising restrictions – final review
(1,000 spots) of all such commercials in Q1 2005 – this share rose to 61.6% (12,000)
in Q1 2009.
6.17
Child impacts for food and drink commercials using a licensed character fell by 84%
(from 0.39bn impacts to 0.06bn impacts). The share of all food and drink impacts that
featured a licensed character fell from 10.7% to 2.2%.The overall reduction was
driven by an 88% (0.34bn) drop in impacts during children’s airtime, however this
was offset slightly by the 69% (0.01bn) increase in impacts during adult airtime.
Children’s airtime continued to carry 72.9% of all licensed character impacts in Q1
2009, indicating that advertisers are using this technique to market non-HFSS
products.
6.18
Although there was an increase in the use of licensed characters in food and drink
advertising in adult airtime, both the overall reduction in the volume of spots
containing this technique and the significant reduction in exposure may suggest that
the growth in advertising activity during adult airtime is not targeted at children.
Celebrities
6.19
Between Q1 2005 and Q1 2009, there was a 573% increase in the number of food
and drink advertisements featuring celebrities (up from 25,000 to 168,000). The
share of food and drink advertising accounted for by these spots increased from
4.3% to 14.9%. Spots increased by 245% (2,000) in children’s airtime and 583%
(141,000) in adult airtime. 98.5% of celebrity food and drink such spots were
delivered during adult airtime in Q1 2009. This may suggest that this particular
technique may be more likely to be used in commercials for products more likely to
appeal to adults. In line with the interim review the majority of celebrities featured in
these advertisements during Q1 2009 appeared to be of primary appeal to adults
(e.g. Ian Botham, Gloria Hunniford).
6.20
Child impacts for food and drink advertisements featuring a celebrity increased by
143% (from 0.2bn to 0.4bn impacts). The share of all food and drink impacts
featuring celebrities grew from 4.6% to 14.8%. Impacts in children’s airtime fell 4%
but increased 153% in adult airtime (0.24bn).
Promotions
6.21
There was a 201% increase in the use of promotions in food and drink advertising
between Q1 2005 and Q1 2009 (up from 42,000 spots to 125,000 spots). In Q1 2005,
this technique appeared in 7.2% of all food and drink advertising spots but in 11.1%
in Q1 2009. There was a 67% (16,000 spots) reduction in the use of promotionsbased advertising during children’s airtime. The effect of this was offset by the 552%
(100,000 spots) growth observed during adult’ airtime.
6.22
There was a 41% fall in child impacts for food and drink advertisements containing
promotions (down from 0.5bn to 0.3bn). The incidence of this technique in all food
and drink impacts fell from 13.2% to 10.3%. There was a 112% (0.1bn) increase in
impacts during adult airtime which partially offset the 82% (0.3bn) reduction in
impacts during children’s airtime during this period. This reduction in child impacts
suggests the increase in spots observed over the same period was not necessarily
targeted at children.
45
HFSS advertising restrictions – final review
Health Claims
6.23
Food and drink commercials carrying a health claim increased by 139% between Q1
2005 and Q1 2009 (from 119,000 to 283,000). As a share of all food and drink
advertising, those containing a health claim grew from 20.6% of spots to 25.1%.
Although spots during children’s airtime fell by 14% (2,000), the decline was offset by
the 156% (166,000) rise in spots during adult airtime. 96.4% (273,000) of the
commercials carrying a health claim were shown in adult airtime in Q1 2009. This
may suggest that this type of advertising is more likely to be used in commercials
aimed at adults.
6.24
Children saw 18% (0.1bn) more commercials featuring a health claim (up from
0.67bn impacts to 0.79bn). As a share of all food and drink impacts those containing
health claims grew from 18.7% to 29.1%. Although exposure to this type of
advertising fell 40% (0.07bn impacts) during children’s airtime, this reduction was
cancelled out by the 36% (0.18bn) growth in impacts during adult airtime, resulting an
overall increase in exposure. Again the majority of children’s exposure to this creative
technique took place in adult airtime, where share increased from 75.7% (0.5bn
impacts) to 87.7% (0.7bn impacts)
Brand Equity Characters
6.25
There was a 58% increase in the number of food and drink spots featuring brand
equity characters between Q1 2005 and Q1 2009 (from 66,000 to 105,000). However
the share of food and drink advertising represented by this technique fell from 11.5%
to 9.3%. Spots in children’s airtime dropped by 59% (24,000 spots) but rose in adult’
airtime by 238% (62,000 spots) which accounted for 84.4% (88,000 spots) of all
brand equity spots aired in Q1 2009.
6.26
There was a 56% reduction in children’s exposure to food and drink commercials
featuring a brand equity character (from 0.7bn to 0.3bn impacts). The overall share of
food and drink impacts for such commercials fell from 18.7% to 10.8%. The reduction
was driven by the 82% (0.46bn) fall in exposure during children’s airtime. This was
only partially offset by the 72% (0.1bn) rise in impacts in adult airtime. Two thirds of
impacts for this technique were in adult airtime in Q1 2009.
Other characters
6.27
Between Q1 2005 and Q1 2009, there was a 174% (from 34,000 to 92,000) increase
in the number of food and drink spots featuring other types of characters. The share
of all food and drink spots containing this technique also increased from 5.8% to
8.2% over the same period. The growth in spots was driven by a 310% (59,000
spots) increase in activity during adult airtime, while spots during children’s airtime
fell slightly (down 5%, around 1,000 spots).
6.28
Children’s exposure to this type of advertising remained stable between the two
periods at 0.3bn impacts (-2%). Due to the fall in total food and drink impacts, the
share of impacts for food and drink advertisements containing other characters
increased from 8.9% to 11.6%. The 26% (0.04bn) reduction in exposure during
children’s airtime was offset by a 36% (0.05bn) increase during adult airtime. This
resulted in growth in the share of impacts (from 38.6% in Q1 2005 to 53.6% in Q1
2009) during adult airtime.
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HFSS advertising restrictions – final review
Annex 1
1 BCAP Scheduling Rules
A1.1
The following rules are included in BCAP’s rules on the scheduling of television
advertisements60.
SECTION 4
Specific Separation Requirements 4.2
GENERAL NOTES:
(i) The term ‘adjacent’ where used in these rules refers to a break immediately
before or after the programme in question.
(ii) The term ‘children’s programmes’ means programmes made for children below
the age of 16.
(iii) Channels devoted to children’s programmes, or whose programmes are or are
likely to be of particular appeal to children, will be unlikely to be able to carry at any
time advertising of the kind restricted under 4.2.1 and 4.2.2 below. Such channels
should also take particular note of 4.2.3 and 4.2.4. Thus, for instance, dedicated
children’s channel’s may not carry any advertising for products or services restricted
under 4.2.1(b) below, namely: lotteries, pools and food or drinks assessed as high in
fat, salt or sugar (HFSS).
(iv) For the avoidance of doubt, any given timing, programme category or age band
restriction subsumes any other less severe restriction. Thus, a ‘post 9pm’ subsumes
both a ‘post 7.30 pm’ as well as the restriction on scheduling in or adjacent to
children’s programmes or programmes likely to have a significant child audience.
Similarly, a prohibition on transmission in ‘children’s programmes’, includes e.g.
programmes made for pre-school children. Particular care needs to be exercised
where a programme for, or likely to be of interest to, children is transmitted late in the
evening or in the small hours, as for example at Christmas. Where such a
programme is transmitted after 9pm, no advertisement carrying a timing restriction
may be transmitted in or around that programme.
Children and young people 4.2.1
(a) The following may not be advertised in or adjacent to children’s programmes or
programmes commissioned for, principally directed at or likely to appeal particularly
to audiences below the age of 18:
(i) alcoholic drinks containing 1.2 per cent alcohol or more by volume; (See also
4.2.5 below) (See note (iii) below on identification of programmes of particular
appeal)
60
The complete rules may be found at the ASA’s website at
http://www.asa.org.uk/cap/codes/broadcast_codes/scheduling/Contents.htm.
47
HFSS advertising restrictions – final review
(ii) gambling except lotteries, football pools, equal chance gaming (under a prize
gaming permit or at a licensed family entertainment centre), prize gaming (at a nonlicensed family entertainment centre or at a travelling fair) or Category D gaming
machines (see 4.2.1(b) below);
(iii) religious matter subject to the rules on Religious Advertising in the BCAP
Television Advertising Standards Code;
(iv) slimming products, treatments or establishments.
(b) The following may not be advertised in or adjacent to children’s programmes or
programmes commissioned for, principally directed at or likely to appeal particularly
to audiences below the age of 16:
(i) lotteries;
(ii) football pools;
(iii) equal chance gaming (under a prize gaming permit or at a licensed family
entertainment centre);
(iv) prize gaming (at a non-licensed family entertainment centre or at a travelling
fair);
(v) Category D gaming machines.
(vi) food or drink products that are assessed as high in fat, salt or sugar in
accordance with the nutrient profiling scheme published by the Food Standards
Agency (FSA) on 6 December 2005.
(c) The following may not be advertised in or adjacent to children’s programmes or
programmes which are of particular appeal to children under 10:
(i) female sanitary protection products.
(d) The following may not be advertised in or adjacent to children’s programmes:
(i) drinks containing less than 1.2 per cent alcohol by volume when presented as low
or no-alcohol versions of an alcoholic drink;
(ii) liqueur chocolates;
(iii) matches;
(iv) medicines, vitamins and other dietary supplements;
(v) trailers for films or videos carrying an 18- or 15- certificate;
NOTES:
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HFSS advertising restrictions – final review
(i) Full details of the FSA’s nutrient profiling scheme are available on the FSA
website at: http://www.food.gov.uk/healthiereating/advertisingtochildren/nutlab/nutprofmod
(ii) The restrictions above include sponsorship of the programme.
(iii) Particular appeal – See ASA Advertising Guidance Note 5 - Audience indexing:
identification of programmes likely to appeal to children and young people.
(iv) Depending on content and, in particular, on the extent and nature of any portrayal of
violence or sexual activity, an alternative timing restriction such as post 7.30pm, post 9pm or
even later may often be appropriate for material in category (d)(v), particularly that which is
18 rated.
(v) Again subject to content, this does not preclude the scheduling in or adjacent to
children’s programmes of advertisements containing brief extracts from films where
these are used in connection with promotional offers derived from films for other
types of product or service.
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HFSS advertising restrictions – final review
Annex 2
2 BCAP Content Rules
A2.1
The following rules are included in BCAP’s current TV Advertising Standards
Code61. A new version of the BCAP code comes into force on 1 September 2010,
however both the scheduling rules (Annex 1) and the content rules (below) for
HFSS advertising remain unchanged.
A2.2
Food and Soft Drink Advertising and Children
On 1 July 2007, a new and important regulation governing nutrition and health claims
for foods came into force. The regulation is complex and mandatory. BCAP
encourages broadcasters to take advice on the effect of the regulation and to consult
the Food Standards Agency’s Guidance to Compliance with Regulation (EC)
1924/2006 on Nutrition and Health Claims on Foods, which is available at
http://www.food.gov.uk
Notes:
1. The rules in 7.2 must be read in conjunction with the other rules in this Code,
especially section 8.3, ‘Food and Dietary Supplements’. For rules on the scheduling
of HFSS product advertisements, please see the BCAP Rules on the Scheduling of
Television Advertisements. References to food apply also, where relevant, to
beverages.
2. The spirit, as well as the letter, of the rules in this section applies to all
advertisements that promote, directly or indirectly, a food or soft drink product.
3. These definitions apply in rule 7.2:
• Children - refers to persons below the age of 16.
• Advertisements targeted directly at pre-school or primary school children –
advertisements that directly target pre-school or primary school children through their
content as opposed to their scheduling. For rules on the scheduling of HFSS product
advertisements, please see the BCAP Rules on the Scheduling of Television
Advertisements.
• Licensed Characters - those characters that are borrowed equities and have no
historical association with the product.
• Equity Brand Characters - those characters that have been created by the
advertiser and have no separate identity outside their associated product or brand.
• HFSS products - those food or drink products that are assessed as high in fat, salt
or sugar in accordance with the nutrient profiling scheme published by the Food
Standards Agency (FSA) on 6 December 2005. Information on the FSA’s nutrient
profiling scheme is available on the FSA website at:
http://www.food.gov.uk/healthiereating/advertisingtochildren/nutlab/nutprofmod
7.2.1 Diet and lifestyle
61
The complete Code may be found at the ASA’s website at http://www.asa.org.uk/cap/codes/.
50
HFSS advertising restrictions – final review
Advertisements must avoid anything likely to encourage poor nutritional habits or an
unhealthy lifestyle in children.
Notes:
(1) This rule does not preclude responsible advertising for any products including
those that should be eaten only in moderation.
(2) In particular, advertisements should not encourage excessive consumption of any
food or drink, frequent eating between meals or eating immediately before going to
bed.
(3) It is important to avoid encouraging or condoning attitudes associated with poor
diets, for example, a dislike of green vegetables.
(4) Portion sizes or quantities of food shown should be responsible and relevant to
the scene depicted, especially if children are involved. No advertisement should
suggest that a portion intended for more than one person is to be consumed by a
single individual or an adult’s portion, by a small child.
(5) Advertisements for food should not suggest that an inactive or sedentary lifestyle
is preferable to physical activity.
7.2.2 Pressure to purchase
Note: Please see also 7.3 (Pressure to purchase)
(a) Although children may be expected to exercise some preference over the food
they eat or drink, advertisements must be prepared with a due sense of responsibility
and should not directly advise or ask children to buy or to ask their parents or other
adults to make enquiries or purchases
Notes:
(1) This extends to behaviour shown: for example, a child should not be shown
asking for a product or putting it into the parent’s trolley in the supermarket.
(2) Phrases such as “Ask Mummy to buy you” are not acceptable.
(b) Nothing in an advertisement may seem to encourage children to pester or make
a nuisance of themselves.
(c) Advertisements must not imply that children will be inferior to others, disloyal or
will have let someone down, if they or their family do not buy, consume or use a
product or service.
(d) Advertisements must neither try to sell to children by appealing to emotions such
as pity, fear, loyalty or self-confidence nor suggest that having the advertised product
somehow confers superiority, for example making a child more confident, clever,
popular, or successful.
(e) Advertisements addressed to children should avoid ‘high pressure’ and ‘hard sell’
techniques, i.e. urging children to buy or persuade others to buy. Neither the words
used nor the tone of the advertisement should suggest that young viewers are being
bullied, cajoled or otherwise put under pressure to acquire the advertised item.
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HFSS advertising restrictions – final review
(f) If an advertisement for a children’s product contains a price, the price must not be
minimised by the use of words such as ”only” or ”just”.
Note:
Products and prices should not be presented in a way that suggests children or their
families can easily afford them.
7.2.3 Promotional offers
Promotional offers should be used with a due sense of responsibility. They may not
be used in HFSS product advertisements targeted directly at pre-school or primary
school children.
(a) Advertisements featuring promotional offers linked to food products of interest to
children must avoid creating a sense of urgency or encouraging the purchase of
excessive quantities for irresponsible consumption.
(b) Advertisements should not seem to encourage children to eat or drink a product
only to take advantage of a promotional offer: the product should be offered on its
merits, with the offer as an added incentive. Advertisements featuring a promotional
offer should ensure a significant presence for the product.
(c) Advertisements for collection-based promotions must not seem to urge children
or their parents to buy excessive quantities of food. They should not directly
encourage children only to collect promotional items or emphasise the number of
items to be collected. If promotional offers can also be bought, that should be made
clear. Closing dates for collection-based promotions should enable the whole set to
be collected without having to buy excessive or irresponsible quantities of the
product in a short time. There should be no suggestion of “Hurry and buy”.
(d) If they feature large pack sizes or promotional offers, e.g. “3 for the price of 2”,
advertisements should not encourage children to eat more than they otherwise
would.
(e) The notion of excessive or irresponsible consumption relates to the frequency of
consumption as well as the amount consumed.
7.2.4 Use of characters and celebrities
Licensed characters and celebrities popular with children must be used with a due
sense of responsibility. They may not be used in HFSS product advertisements
targeted directly at pre-school or primary school children.
Notes:
(1) Advertisements must not, for example, suggest that consuming the advertised
product will enable children to resemble an admired figure or role-model or that by
not doing so children will fail in loyalty or let someone down.
(2) This prohibition does not apply to advertiser-created equity brand characters
(puppets, persons or characters), which may be used by advertisers to sell the
products they were designed to sell.
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HFSS advertising restrictions – final review
(3) Persons such as professional actors or announcers who are not identified with
characters in programmes appealing to children may be used as presenters.
(4) Celebrities and characters well-known to children may present factual and
relevant generic statements about nutrition, safety, education, etc.
8.3 Food and dietary supplements
Notes:
(1) The rules in 8.3 must be read in conjunction with the relevant legislation including
the Food Labelling Regulations 1996 (as amended) and especially Schedule 6. They
apply to all advertising for food products. If an advertisement is targeted at children,
Section 7 of this Code also applies. For HFSS product advertisements scheduled in
and around programmes of particular appeal to children, please see the BCAP Rules
on the Scheduling of Television Advertisements.
(2) Public health policy increasingly emphasises good dietary behaviour and an
active lifestyle as a means of promoting health. Commercial product advertising
cannot reasonably be expected to perform the same role as education and public
information in promoting a varied and balanced diet but should not undermine
progress towards national dietary improvement by misleading or confusing
consumers or by setting bad examples, particularly to children. Advertisements for
food should not suggest that an inactive or sedentary lifestyle is preferable to
physical activity.
(3) The spirit, as well as the letter, of the rules in this section applies to all
advertisements that promote, directly or indirectly, a food or soft drink product.
8.3.1 Accuracy in food advertising
(a) Nutrition claims (e.g. “high in vitamin C”) or health claims (e.g. “aids a healthy
digestion”) must be supported by sound scientific evidence. Advertising must not
give a misleading impression of the nutritional or health benefits of the product as a
whole and factual nutrition statements should not imply a nutritional or health claim
that cannot be supported. Ambiguous wording that could be understood as a health
claim must be avoided. For example, “goodness” should not be used as a synonym
for “wholesomeness” and, if a claim relates to taste, that should be made clear, e.g.
“It tastes good”, not “It is good”. The scientific meaning of the word “energy”, i.e.
calorific value, should not be confused with its colloquial meaning of physical vigour
(b) Nutritional claims and health claims should relate to benefits that are significant.
Claims should be presented clearly and without exaggeration
(c) No nutritional or health claim may be used in HFSS product advertisements
targeted directly at pre-school or primary school children
Notes:
(1) Advertisements targeted directly at pre-school or primary school children are
advertisements that directly target pre-school or primary school children through their
content as opposed to their scheduling. For rules on the scheduling of HFSS product
advertisements, please see the BCAP Rules on the Scheduling of Television
Advertisements.
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HFSS advertising restrictions – final review
(d) The fact that a food product is a good source of certain nutrients does not justify
generalised claims of a wider nutritional benefit
Notes:
(1) Claims of nutritional or health benefits should be considered in the context of a
balanced diet or lifestyle or both. For the avoidance of doubt, HFSS product
advertisements may make nutritional or health claims in accordance with 8.3.1.
8.3.2 Excessive consumption
Advertisements must not encourage or condone excessive consumption of any food
Notes:
(1) Interpretation of this rule should be by reference to generally accepted nutritional
advice. It would clearly not be inconsistent with shots of someone enjoying a
chocolate bar; it would, however, preclude someone being shown eating whole
boxes of chocolates in one sitting.
(2) Portion sizes or quantities of food shown should be suitable for the occasion and
the people portrayed, especially if children are involved. Advertisements should not
suggest that a portion intended for more than one person is to be consumed by a
single individual or an adult’s portion, by a small child.
(3) If they feature large pack sizes or promotional offers, e.g. ”3 for the price of 2”,
advertisements should not encourage people to eat more than they otherwise would.
(4) The notion of excessive consumption relates to the frequency of consumption as
well as the amount consumed.
8.3.3 Comparisons and good dietary practice
Advertisements must not disparage good dietary practice. Comparisons between
products must not discourage the selection of options such as fresh fruit and
vegetables, which accepted dietary opinion recommends should form a greater part
of the average diet
Notes:
(1) Advertisements should not seem to contradict or ignore good dietary practice.
(2) To reflect generally accepted good dietary practice, a reasonable variety of other
foods should be shown if the advertised product is presented as part of a meal.
(3) Food products not intended as substitutes for meals should not be presented as
such.
8.3.4 Oral health
Advertisements must not encourage or condone damaging oral health care practices
Note:
For instance, advertisements must not encourage frequent consumption throughout
the day, particularly of potentially cariogenic products such as those containing
sugar. This rule has children’s dental health particularly in mind.
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HFSS advertising restrictions – final review
8.3.5 Dietary supplements
(a) Advertisements must not suggest that it is necessary for the average person to
augment the diet or, unless the claim is authorised by the European Commission,
that dietary supplements can enhance normal good physical or mental condition.
Claims about higher vitamin or mineral intake for a specific function are permitted if
authorised by the European Commission.
(b) Advertisements may offer vitamin and mineral supplements to certain groups as
a safeguard to help maintain good health. If the claim made for a vitamin or mineral
supplement is relevant only to a group that is at risk of inadequate intake, the
advertisement must state clearly the group likely to benefit from a particular form of
supplement
Note to 8.3.5(b):
Only certain groups are likely to benefit from particular vitamin or mineral
supplements. They might include people on a restricted dietary regimen, those
eating unsupplemented, low-energy diets, women of child-bearing age (particularly if
they are planning to have a baby, are pregnant or lactating), growing children and
some individuals over 50.
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HFSS advertising restrictions – final review
Annex 3
3 Channel & airtime definitions
Children’s airtime definition
A3.1
Children’s airtime is defined by combining specific children’s slots/strands on the
main PSB channels with dedicated children’s channels. There are no dedicated
children’s slots on the non-PSB mixed genre channels.
A3.2
Figure A1 lists the children’s channels available between 2003-2009. Some
channels have changed brand names over time (such as Jetix), some (like Pop+1)
have ceased transmission. It should be noted that some channels do not carry
commercial advertising (e.g. CBBC and most Disney channels).
Figure A1: Children’s channels
Dedicated children’s channels
Baby TV
Disney Cinemagic
Playhouse Disney
Boomerang
Disney Cinemagic +1
Playhouse Disney +1
Disney XD (formerly Fox
Boomerang+1
Kids/Jetix)
Pop
Cartoon Network
Disney XD+1
Pop+1
Cartoon Network Plus
Kix
Pop Girl
Cartoon Network Too
(formerly Toonami)
Nick Jr
Pop Girl+1
Cartoonito (formerly Cartoon
Network Too)
Nick Jr2
Tiny Pop
CBBC
Nickelodeon
Tiny Pop+1
CBeebies
Nickelodeon Replay
Toon Disney
CITV
Nicktoons
Trouble (excluded from 2006+)
Nicktoons Replay (formerly
Discovery Kids
Nicktoons 2/ NickToonsters)
Trouble +1 (excluded from 2006+)
Disney Channel
Nicktoonster
Disney Channel +1
Note: Disney channels apart from Disney XD do not carry commercial advertising
A3.3
62
Figure A2 below shows those periods of the PSB channel schedules comprising
children’s airtime between 2003 and 2009. It is important to note that day parts may
vary throughout the year due to changes in schedules. The definitions are designed
to enable us capture as much of the airtime during which children’s programming is
broadcast as possible for our analysis. It may be that on occasions schedules have
changed and children’s programming has been replaced with another programme
genre (e.g. football or motor racing on weekend mornings); as a consequence
commercials for HFSS products may have been shown – this may result in data
suggesting some HFSS advertising has aired during “children’s airtime” in 200962.
The analysis presented in Annex 5 does not suggest there are many instances where HFSS advertising has
appeared around adult programming at times when children’s programmes are normally scheduled.
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HFSS advertising restrictions – final review
Figure A2: Children’s airtime definitions
2003
2004
2005
2006
BBC1
Mon-Fri 1525-1735
BBC1
Mon-Fri 1525-1735
BBC1
Mon-Fri 1525-1735
BBC1
Sat 0600-1200
BBC1
Sat 0600-1200
BBC1
Sat 0600-1200
BBC1
Mon-Fri 1525-1735
BBC2
Mon-Fri 0600-1030
BBC2
Mon-Fri 0600-1030
BBC2
BBC2
Sun 0600-1030
BBC2
Sun 0600-1030
BBC2
Mon-Fri 0600-1030
BBC2
Mon-Fri 0700-1030
Sun 0600-1030
BBC2
Sat 0600-1200
BBC2
Sun 0600-1000
ITV1
Mon-Fri 1515-1700
ITV1
Mon-Fri 1515-1700
ITV1
Mon-Fri 1515-1700
ITV1
Mon-Fri 1500-1630
ITV1
Sat 0600-1300
ITV1
Sat 0600-1300
ITV1
Sat 0600-1300
ITV1
Sat 0600-1130
ITV1
Sun 0600-1100
ITV1
Sun 0600-1100
ITV1
Sun 0600-1100
ITV1
Sun 0700-1030
C4
Mon-Fri 0600-0700
C4
Mon-Sun 0600-0700
C4
Mon-Sun 0600-0700
C4
Mon-Sun 0600-0700
C4
Sat 0600-0700
C4
Sun 0600-0900
Five
Mon-Fri 0630-0930
Five
Mon-Fri 0630-0930
Five
Mon-Fri 0630-0930
Five
Mon-Fri 0600-0900
Five
Sat 0700-1330
Five
Sat 0700-1330
Five
Sat 0700-1330
Five
Sat 0700-1130
Five
Sun 0630-1230
Five
Sun 0630-1230
Five
Sun 0630-1230
Five
Sun 0600-1230
2007
2008
2009
BBC1
Mon-Fri 1525-1735
BBC1
Mon-Fri 1505-1710
BBC1
Mon-Fri 1505-1710
BBC2
Mon-Fri 0700-1030
BBC2
Mon-Fri 0600-1100
BBC2
Mon-Fri 0600-1100
BBC2
Sat 0600-1200
BBC2
Sat 0600-1300
BBC2
Sat 0600-1400
BBC2
Sun 0600-1000
BBC2
Sun 0600-1000
BBC2
Sun 0600-1000
ITV1
Sat 0600-1200
ITV1
Sat 0600-1100
ITV1
Sat 0600-1000
ITV1
Sun 0600-1130
ITV1
Sun 0600-1030
ITV1
Sun 0600-1000
C4
Mon-Sun 0600-0700
C4
Five
Mon-Fri 0600-0900
Five
Five
Sat 0700-1000
Five
Sun 0600-1000
Mon-Sun 0600-0700
C4
Mon-Sun 0600-0700
Mon-Fri 0600-0900
Five
Mon-Fri 0600-0915
Five
Sat 0700-1000
Five
Sat 0700-1000
Five
Sun 0600-1000
Five
Sun 0700-1030
Note: 2008 dayparts may vary from the 2008 review (which covered the January-June 2008 period)
due to changes in children’s airtime during the second half of the year
Other channel definitions
A3.4
All other airtime (i.e. that which excludes children’s channels and children’s strands
on the main PSB channels) has been referred to as ‘adult’ airtime. This definition
covers airtime not specifically targeted at children, but during which children may be
watching, on the main PSB channels as well as on all other channels. Within adult
airtime there are some specific channel groups that have been created to
understand trends in more detail. These groups are:
Figure A3: BBC portfolio channels
BBC
BBC3
BBC4
BBC News 24
BBC Parliament
(CBBC)
(CBeebies)
Note: When analysing ‘adult’ airtime, children’s channels CBBC and CBeebies have been excluded
from the definition of BBC portfolio channels.
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HFSS advertising restrictions – final review
Figure A4: Commercial PSB portfolio channels
ITV
ITV2
ITV2 +1
ITV3
ITV3 +1
ITV4
ITV4+1
ITV Play
(CITV)
ITV News
Channel 4
Five
Channel 4+1
Fiver/Five Life
Film4
Fiver +1
Film4 +1
Five US
FilmFour Extreme
Five US +1
FilmFour Weekly
FilmFour World
E4
E4+1
More4
More4 +1
4Music(2008+)
Note: Channel 4+1 has been treated as a commercial PSB portfolio channel throughout this analysis.
When analysing adult airtime, children’s channel CITV has been excluded from the definition of
commercial PSB portfolio channels.
Figure A5: Music channels
Music channels
Bedroom TV
Bliss
Bubble Hits
Channel AKA/Channel U
Channel Starz/Channel Fizz
Chart Show TV
Clubland TV
Flaunt
Flava/B4
Kerrang
Kiss TV
Magic TV
MTV/MTV One
MTV +1/MTV Flux
MTV Base
MTV Dance
MTV Hits
MTV R
MTV Two
Musflash TV
Music Choice
NME TV
Omusic
p-rock
Q Channel/Box TV
Rockworld TV
Scuzz
Smash Hits
The Box
The Vault
VH1
VH1 Classic
VIVA/TMF
The Hits ( 4Music from 2008)
Note: The Hits was removed from the music channels group in 2008 and 4Music added to the
commercial PSB portfolio channels group
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HFSS advertising restrictions – final review
Annex 4
4 Food and Drink definitions used in the
review
A4.1
In Section 3 we explain why it has been necessary to update the way we measure
HFSS impacts. The following subsections in this annex provide a detailed inventory
of each of the product categories or actual products that are included in each
measure.
Data definitions: Food and drink
A4.2
Industry databases (such as those provided by Nielsen Media or Billets Media)
classify food and drink advertising by product and retail category. The difficulty in
establishing the nutrient profile status of adverts means these databases have not
classified products by whether or not they are HFSS.
Nielsen Media
A4.3
Since 2004, Ofcom has based its analysis of food and drink advertising on the
Nielsen Media product categories listed in Figure A6. In broad terms, these
comprise all food products, soft drinks and beverages. They also include advertising
for so-called ‘chain restaurants’63 such as those operated by Burger King or
McDonald’s. In Ofcom publications between 2004 and 2007, these food and drink
categories have been referred to as ‘core categories’.
A4.4
Analysis is based on Nielsen Media ‘product’ categories as opposed to ‘advertiser’
categories, for example a commercial for Kelloggs Coco Pops advertised by
Sainsbury’s is found in the product category ‘Food’ rather than in ‘Retail’. In this way
all food and drink supermarket advertising is captured.
A4.5
Data on food and drink advertising will include both HFSS and non-HFSS products.
Therefore analysis of food and drink advertising by different types of airtime may
show food and drink advertising activity during children’s airtime.
Figure A6: Food and drink advertising – Nielsen product categories
02 FOOD
01 Bakery
Goods
05 Biscuits
10 Bread & Bakeries 15 Cakes & Fruit
Pies
20 Cakes (frozen)
05 Cereal Bars
10 Chewing Gum
15 Choc Bars
&Count
20 Chocolate-Boxed
25 ChocolateOther
30 Ice Cream &
Lollies
35 Sugar
Confection
40 Mixed/Gen
confect
25
Crispbrd/Crackers
02
Confectionery
63
The Nielsen Media database, which was used in the 2004 analysis (and subsequent analysis), does not
contain a ‘fast food’ product category. ‘Fast food’ advertising is classified under Nielsen’s ‘Chain Restaurants’
sub-category and has therefore been the label used across all Ofcom’s analysis in this area.
59
HFSS advertising restrictions – final review
05 Cakes & Pastry
03
CookingProd & Mix
Seasoning
25 Meat & Veg
Extract
10 Condiments,
15 Cooking Fats
Sauces & Dressings
20 Flour & Baking
Pow
30 Sauce (Cook &
Mix)
45 Sugars
46 Artificial
Sweetener
20 Eggs
04 Dairy
Products &
Substitutes
05 Butter
10 Cheese
15 Cream & Subs
25 Margarine
30 Milk & Milk Prod
35
99 Dairy Range
Yoghurt/FromFrais
06 Fruit, Veg,
Pasta
05 Fruit (Canned)
10 Fruit (Dried)
15 Fruit (Fresh)
30 Veg & Pasta
(Can)
35 Vegetable
(Fresh)
40
Vegetable(Frozen)
10 Fish (Canned)
15 Fish (Fresh
Frozn)
20 Sl
Meat,Sprd,Pate
25 Meat Poultry
(Can)
30 Meat(Fresh
Frozn)
35 Meat Pies
Sausage
40 Poult (Fresh
Frozn)
05 Baby Foods
10 Cereal(Ready
Eat)
15 Cereal
(Prepare)
20 Conven. Desserts
25
27 Pizza – Frozen
Deh,CanReadyEat
30 Prep Food
Range
35 Froz Ready
Meals
40 Jams &
Spreads
45 Soup (Canned)
50
55
Soup(Pack)Dry&Fr PotatoCrispSnack
56
Dips/DipperSnack
91 Pre/Con Food
Gen
07 Meat, Fish & 05 Bacon
Poultry
08 Prepared &
Convenience
Foods
09 Organic
Rnge
05 Organic Foods
90 FoodSponsor
15 Other
Sponsorshp
99 Food Corp
99 Food Corp
25 Rice Pasta
(Dr&Fr)
04 DRINK
02 Soft Drinks
04 Beverages
05 Soft Drink Mixer 07 Mineral Water
10 Cordials/squash 15 Fr Juice/St
FrDrink
20 Other
Carbonated
25
Athlete/Hlth/Energ
95 Soft Drinks Gen
05 Coffee (Fresh)
10 Coffee (Instant)
15 Health Drinks
20 Tea
25 Other
Beverages
30 RETAIL
15 Chain
Restaurant
01 Ent &
Leisure
Note: Some category names have been abbreviated from the original Nielsen Media labels.
Some category labels may vary from previous analysis.
Billets Media
A4.6
60
In addition to the scheduling restrictions introduced in 2007, rules restricting the use
of particular techniques calculated to appeal to children in food and drink
advertising (including some applying specifically to HFSS advertising) were also
adopted (see Annex 2).
HFSS advertising restrictions – final review
A4.7
We have used data from Billets Media (formerly known as Thomson Intermedia) for
the purposes of analysing the use of these techniques (Section 6 and Annex 7).
The database contains data on creative techniques for all food and drink product
advertising from 2003 to March 2009. As only Q1 data is available for 2009 we have
compared this with the same period in 2005. It should be noted that due to
seasonality in food and drink advertising trends, this analysis based on data for Q1
2005 and Q1 2009 provides a snapshot of activity over that period.
A4.8
In this analysis, adverts are subject to multiple coding, to take account of adverts in
which more than one of the creative techniques is used. For example, in the case of
a popular cereal (such as Frosties) including an offer for children’s books, the
advert would be coded twice; once for the use of a brand equity character (Tony the
Tiger) and once for the use of promotions. Billets’ food and drink categories differ in
some details from the definition of food and drink advertising used elsewhere in the
review.
A4.9
The full list of Billets food and drink product and retail categories is set out in Figure
A7. In summary, they cover almost all food and drink advertising, including:
a) all food and drink categories (except tea and coffee);
b) department stores (advertisements for food and drink products, as well as
restaurants);
c) supermarkets (advertisements for specific food and drink products, as well as
food and drink ranges); and
d) other (advertising for fast food, confectionery, restaurants and bars).
Figure A7: All food and drink – definition based on Billetts’ categories
FMCG
Confectionery
Cereal Bars
Chewing Gum
Chocolate
Potato Crisps & Snacks
Sugar Confectionery
Drinks – Beverages
Chocolate
Drinks – Non Alcoholic
Carbonated Soft Drinks
Cordial & Squash64
Energy Drinks
Fresh Fruit Juice
Milk Shakes & Derivatives
Mineral Water
Biscuits
Breads & Bakeries
Cakes & Fruit Pies
Crispbreads & Savoury Biscuits
Fish
Fruit
Meat & Poultry
Vegetables & Pasta
Food - Cereal
Ready to Eat
Requiring Preparation
Food - Cooking Ingredients
Cakes & Pastry Mixes
Cooking Oils & Fats
Flour
Herbs & Spices
James & Preserves
Rice & Pasta
Food - Bakery Goods
Food - Canned
Sugar & Sweetners
64
There has been a name change to the category previously listed as ’04.02.10 Cordials’ to ’04.02.10
Cordials/squash’
61
HFSS advertising restrictions – final review
Food - Dairy
Butter/Margarine
Cheese
Cream & Substitutes
Eggs
Ice Cream
Milk & Milk Products
Yoghurt & F/Frais
Food - Food Range
Food Range
Food - Fresh
Fish
Fruit & Nuts
Meat & Poultry
Pasta
Spreads, Pates & Sliced Meats
Vegetables
Desserts
Fish
Frozen – Range
Meat & Poultry
Food - Frozen
Vegetables
Food - Ready To Eat Meals
Baby Food
Convenience Dessert
Dehydrated
Fresh Chilled
Frozen
Microwave
Food – Sauces & Condiments
Bottled Sauces
Salad Dressings
Food - Soup
Bottled
Canned
Packet
Food - Vegetarian
Vegetarian – Range
Department
Drink
Food
Restaurant
Food & Drink
Drink
Food
Retail
Mail Order
Food & Drink
Price Comparison Sites
Stores
Stores - Supermarket
Drink
Food
Food & Drink
Stores (Fast Food/ Restaurants)
Drink
Food
Supermarket – Range
Food & Drink
Data definitions: 2005 HFSS proxy
A4.10
In 2006, Ofcom modelled the potential effects of different approaches to restricting
advertising of HFSS products. For this purpose, it was necessary for Ofcom to
reach a view on how much food and drink advertising in 2005 (the latest year for
which full data was available) was for HFSS products.
A4.11
As the FSA’s nutrient profile model was not finalised and because it would have
been impracticable to profile several thousand food and drink products, Ofcom
sought the help of the Institute of Practitioners of Advertising (IPA) in reaching a
view on which Nielsen product categories were likely to consist predominantly of
HFSS products on the basis of the FSA’s provisional nutrient profiling model. As a
result, the Nielsen food and drink minor product categories listed in Figure A8 were
assumed to comprise non-HFSS products, and the remainder to comprise HFSS
products. Ofcom used this definition as a proxy (‘the 2005 HFSS proxy’) for
modelling how much food and drink advertising in 2005 was for HFSS products.
This proxy was used to estimate the likely impact of the restrictions on children’s
exposure to HFSS advertising (i.e. a 41% reduction in exposure for children aged 415).
62
HFSS advertising restrictions – final review
A4.12
The 2005 proxy was necessarily approximate – some of the minor product
categories excluded by the IPA (such as ‘meat and vegetable extracts’) may have
included HFSS products, while some of those included (such as’ ready-to-eat
cereals’) may have included non-HFSS products. However, in the absence of
definitive data, it represented the best available basis for estimating how much
advertising in 2005 was for HFSS or non-HFSS products. This measure has been
used again in this review as an estimate of HFSS advertising in 2005 – the base
year against which 2009 activity has been compared.
Figure A8: 2005 HFSS proxy – Nielsen Media minor product categories excluded from
the food and drink definition (Figure A6) to derive the 2005 HFSS proxy
Products excluded
02.03.10 Condiments, Sauces & Dressings
02.03.25 Meat & Vegetable Extracts
02.06.25 Rice & Pasta (dried & fresh)
02.06.30 Vegetables & Pasta (canned)
02.06.35 Vegetables (fresh)
02.06.40 Vegetables (frozen)
02.07.10 Fish (canned)
02.07.15 Fish (fresh & frozen)
02.07.30 Meat (fresh & frozen)
02.08.05 Baby foods
02.08.25 Dehydrated, Canned Ready to Eat
04.02.07 Mineral Water
04.02.10 Cordials/squash
04.02.15 Fruit Juice/Still Fruit Drink
04.04.10 Coffee (instant)
04.04.15 Health Drinks
04.04.20 Tea
A4.13
In order to compare aspects of the data in 2005 and 2009 (including HFSS spot
data) for this review, it has been necessary to re-run the 2005 data. Since the 2008
review, which reported changes in exposure to HFSS advertising using the 2005
HFSS proxy definition there has been a change in one of the Nielsen product
categories that affect the definition of the 2005 HFSS proxy used in this review.
A4.14
The minor product category referred to in both Ofcom’s 2006 modelling work to
determine the volume of HFSS advertising in 200565 and in the interim review as
‘02.03.10 Condiments’, has now changed to ‘02.03.10 Condiments, Sauces and
Dressings’. This new category brings together the previously separate minor
product categories ’02.03.10 Condiments’ and ’02.03.35 Sauces’.
A4.15
Based on the definition of the 2005 HFSS proxy used in the 2008 review, ‘02.03.10
Condiments’ would have been treated as non-HFSS and therefore excluded from
the proxy definition – while the ‘02.03.35 Sauces’ category was treated as HFSS
and included in the proxy definition.
A4.16
As a result of the change in Nielsen categories the ’02.03.10 Condiments, Sauces
and Dressings’ category has been treated as non-HFSS in this review. Therefore
data based on the 2005 HFSS proxy definition excludes all products within the new
’02.03.10 Condiments, Sauces and Dressings’ sub-category. As a result of this,
figures based on the 2005 HFSS proxy in this review vary from those reported in
the 2008 review. The total figure for HFSS advertising in 2005 used in this review is
0.4bn impacts smaller (at 12.1 billion impacts) than the 12.5bn impact base figure
reported in the interim review. The lower 2005 base figure means that any
comparison with the 2009 data will show slightly smaller reductions in HFSS
65
Documents can be found at http://www.ofcom.org.uk/consult/condocs/foodads_new/
63
HFSS advertising restrictions – final review
impacts than would be the case if it had been possible to make comparisons with
the original 2005 data.
Data definitions: 2009 HFSS proxy
A4.17
Since the introduction of the HFSS advertising restrictions in 2007, it has been
possible to make more robust estimates of what constitutes HFSS advertising.
Advertisers wishing to place their products in children’s airtime are now obliged to
certify in accordance with the FSA’s nutrient profiling scheme that their
advertisements are for non-HFSS products. Clearcast, the body entrusted by many
broadcasters with checking that advertisements comply with these restrictions will
only advise broadcasters that an advertisement may be shown in children’s airtime
on this basis. It is for broadcasters to ensure they comply. Clearcast have provided
Ofcom with data on which individual advertisements were certified as non-HFSS in
2009. By comparing this with a list of the products advertised in 2009 at a ‘brand’
level66 from the Nielsen Media database, it was possible to determine how much
advertising seen by children had been certified as non-HFSS. The process of
matching Clearcast data with Nielsen Media data was conducted at the granular,
advert-by-advert, level using ‘film numbers’ – these are codes assigned to individual
advert creatives.
A4.18
However the majority of advertisements are not certified. If an advertiser has
products that they do not want to place in children’s airtime or around programmes
of particular appeal to children (e.g. sparkling water or coffee), it is not necessary
for those advertisements to be certified and they will be scheduled in adult airtime.
In these cases, it was necessary to assess whether the products advertised were
likely to be HFSS or non-HFSS.
A4.19
As data on an advert-by-advert basis is too granular to be used in our analysis of
children’s exposure to HFSS advertising, we had to make some simplifying
assumptions, and aggregate the individual advert data at ‘brand level’. We looked at
all uncertified food and drink brands (as labelled by Nielsen Media), and made an
assessment as to whether they were likely to be for HFSS or non-HFSS products.
In many cases, it was apparent whether or not a product was HFSS from the ‘brand’
label. For example, it is reasonable to assume that well-known chocolate bars are
HFSS products, but that spring water is not. Where there was doubt, we classified
products as HFSS.
A4.20
There are cases in the Nielsen database where data at the ‘brand’ level is used to
describe a range of products or include a range of advertisements, some of which
are for HFSS products, others for non-HFSS products. In these instances, it was
necessary to decide whether the products described by the ‘brand’ label should be
regarded as HFSS or non-HFSS (accepting that a number of advertisements would
be miscategorised as a result). The attribution was determined by whether the
majority of adverts within the relevant ‘brand’ were assessed as HFSS or non-HFSS
advertising. It is likely that the net effect of this approach is to slightly overstate the
proportion of advertising in 2009 that was for HFSS products.
66
Data available on the Nielsen Media database at the ‘brand’ level varies in form across advertisers. For
example, at the ‘brand’ level there is only one brand to cover all television advertising conducted by McDonald’s
(‘McDonalds - Restr Chain’) but advertising for KitKat products is broken down to a number of brands (‘KitKatChocolate Bar’, ‘KitKat- Chunky Caramel Bar’, ‘KitKat – Senses’). Each ‘brand’ may consist of a number of
different commercials or film numbers.
64
HFSS advertising restrictions – final review
A4.21
Having categorised the ‘brands’ in this way and generated data on HFSS
advertising activity we found that the data suggested children were being exposed
to HFSS commercials during children’s airtime in 200967 (in the region of 0.4bn
impacts). On further investigation we found that these commercials fell under the
‘McDonalds – Restr Chain’ brand. This particular ‘brand’ comprises over 100
different commercials. Based on the approach described above, the entire ‘brand’
was classified as HFSS. However as the McDonalds’ commercials shown in
children’s airtime were certified as non-HFSS, we have counted them as such to
avoid misrepresenting the position and to present the most accurate picture
possible of advertising activity during children’s airtime. These specific non-HFSS
McDonald’s commercials were therefore considered non-HFSS for the analysis of
children’s exposure to HFSS advertising in 2009. It is important to note that some of
these certified non-HFSS McDonald’s commercials were also shown during adult
airtime and by excluding these specific commercials from the definition of HFSS
brands, they will have been considered non-HFSS wherever they appeared in adult
airtime.
A4.22
The categorisation of brands is detailed in Figure A9 and Figure A10.
Figure A9: 2009 HFSS proxy – Brands assessed as non-HFSS
Non-HFSS brands
ALBERT BARTLETT - ROOSTER
POTATOES
HOVIS - ROLLS RGE
QUORN - PROD RGE
ALPRO - SOYA MILK
HOVIS - SEED SENSATIONS BREAD
RED BULL - SUGARFREE
ALPRO SOYA - LIGHT MILK
ROBINSONS - FRUIT SHOOT
ASDA - BREAD RGE
ICELAND - FROZEN VEGETABLES
ICELAND - KING PRAWN KEBAB
SELECTIO
ASDA - FRUIT
INNOCENT - SMOOTHIES
SAINSBURYS - EGGS
ASDA - RUMP STEAK
INNOCENT - SMOOTHIES FOR KIDS
SAINSBURYS - FRESH FRUIT
ASDA - TURKEY
INNOCENT - VEG POTS
AUNT BESSIES - PROD RGE
ISKLAR - MINERAL WATER
SAINSBURYS - GRAPES
SAINSBURYS - JERSEY ROYAL
POTATOES
AVONMORE SUPERMILK
JOHN WEST - NO DRAIN TUNA
SAINSBURYS - RED LABEL TEA
BARRYS GOLD BLEND TEA
JOHN WEST - TINNED TUNA
SAINSBURYS - SALMON
BARRYS TEA/GOLD BLEN
KELLOGGS - OPTIVITA
BATCHELORS SQUEEZ
KENCO - INSTANT COFFEE
SAINSBURYS - STRAWBERRIES
SAINSBURYS - TASTE DIFF KING
PRAWNS
BENECOL - FRUIT & DAIRY SMOOTHIE
KENCO - PURE RGE
SAINSBURYS - VEG RGE
BIO SYNERGY - SKINNY WATER
KINGSMILL - 50 50 BREAD
SCHWEPPE OASIS DRINK
BIRDS EYE - FIELD FRESH GDN PEAS
KINGSMILL - GREAT EVERYDAY BREAD
SCOTTISH DAIRY MRKTG - MILK
BIRDS EYE - OMEGA 3 FISH FINGERS
BIRDS EYE - REGGAE REGGAE CHICKEN
C
BLUEBERRIES FROM SOUTH BLUEBERRY
KINGSMILL - LITTLE BIG LOAF RGE
KINGSMILL WHOLEMEAL
SHARWOODS - BOMBAY POTATOES
SHARWOODS - CANTONESE CURRY
SAUCE
LACTOFREE - SEMI SKIMMED MILK
SHARWOODS - MICROWAVE NOODLES
BRACE'S BAKERY
LAILA - FLOUR RGE
SIMPLY FISH
BRENNANS BREAD
LAVAZZA - ESPRESO COFFEE
SMA - FOLLOW ON MILK
BROOKE BOND PG TIPS
LIDL - FRUIT & VEG
SMA - PROGRESS MILK
BUXTON SPRING WATER
LITTLE DISH - READY MEALS
SMA - TODDLER MILK
CAPRI-SUN FRT DRINK
LYONS IRELAND - TEA
SOMERFIELD - BEEF
COCA COLA - COCA COLA ZERO
MAXWELL HOUSE
SOMERFIELD - CHICKEN
COCA COLA - DIET COKE
MCCAIN - PROD RGE
SOMERFIELD - COOKED HAM
COOP - BAKING POTATOES
MCCAIN - RUSTIC OVEN CHIPS
SOMERFIELD - DRY CURED HAM
COOP - CLEMENTINES
MCCAIN - SMILES
SOMERFIELD - LEAN STEAK MINCE
ROOSTER - IRISH POTATOES
67
Since 1 January 2009, the scheduling rules have prohibited the advertising of HFSS foods during any
children’s airtime.
65
HFSS advertising restrictions – final review
COOP - COX APPLES
MCCAIN - SWEET POTATO
SOMERFIELD - PORK
COOP - FRESH CHICKEN
MCCAIN - WEDGES
SOMERFIELD - POTATOES
COOP - FRESH VEG
MCCAIN HOME FRIES
SOMERFIELD - STEAK
COOP - HOVIS BREAD
MCCAIN OVEN CHIPS
SOMERFIELD - STRAWBERRIES
COOP - JOHN WEST WILD RED SALMON
MCDONALDS - RESTR CHAIN*
COOP - NESCAFE ORIG COFFEE
MEAT & LIVESTOCK COMM - MINCE
SOMERFIELD - TETLEY TEA BAGS
SOMERFIELD - YOUNGS SALMON
FILLETS
COOP - PG TIPS
MILUPA - APTAMIL FOLLOW ON
STARBUCKS COFFEE - COFFEE
COOP - SALMON
MORRISONS - BREAD RGE
STRATHMORE - SPRING WATER
COOP - WARBURTONS BREAD
COOP - WARBURTONS SLICED WHITE
ROLL
COW & GATE - BABY BALANCE
PORRIDGE
MORRISONS - BRIT NEW POTATOES
SUNNY DELIGHT
MORRISONS - COD FILLETS
SUSO - DRINKS RGE
MORRISONS - COX APPLES
COW & GATE - BABY BALANCE RGE
MORRISONS - DRINK RGE
TAYLORS - YORKSHIRE TEA
TAYLORS - YORKSHIRE TEA HARD
WATER
COW & GATE - COMP CARE FOLLOW ON
COW & GATE - COMP CARE GROWING
UP
MORRISONS - FRESH FISH RGE
TESCO - HOT CROSS BUNS
MORRISONS - FRESH SCOT SALMON
TETLEY - REDBUSH
CRAVENDALE - MILK
MORRISONS - FRESH VEGETABLES
DALE FARM - ONE PERCENT MILK
MORRISONS - FRUIT
DANONE - ACTIMEL
MORRISONS - FRUIT & VEG
TETLEY GREEN TEA RGE
TIPPERARY - NATURAL MINERAL
WATER
TREBOR BASSETT - EXTRA STRONG
GUM
DANONE - ACTIVIA FIBRE YOGHURT RGE
MORRISONS - HADDOCK FILLETS
TRIDENT - SUGARFREE GUM
DANONE - ACTIVIA INTENSELY CREAMY
MORRISONS - JERSEY ROYALS
TROPICANA
DANONE - ACTIVIA YOGURTS RGE
MORRISONS - KING PRAWNS
TWININGS - ENGLISH BREAKFAST TEA
DANONE - BIO ACTIVIA YOGHURT
MORRISONS - PG TIPS
TWININGS - LADY GREY TEA
DANONE DANACOL YOGHURT
MORRISONS - PRINCES RED SALMON
TWININGS - SPECIALITY TEA
DANONE DANONINO
MORRISONS - SALMON FILLETS
TWININGS - TEA RANGE
DANONE SHAPE YOGURT
TWININGS EVERY DAY TEA
DENNY IRE - HAM
MORRISONS - SCOTCH BEEF
MULLER - CORNER HEALTHY BALANCE
YOG
DOLMIO - BOLOGNESE SAUCE
MULLER - LITTLE STARS RGE
UNCLE BENS - BOIL IN A BAG RICE
DOLMIO - LASAGNE SAUCE RGE
MULLER - MULLER LIGHT YOGHURT
VOLVIC
DOLMIO - MY DOLMIO KIDS RGE
MULLER - MULLERICE
WARBURTONS BREAD
DOLMIO - SAUCE RANGE
MUNCH BUNCH - DOUBLE UP YOGHURT
WARBURTONS CRUMPETS
DOLMIO - STIR IN SAUCE
MUNCH BUNCH - YOGHURTS
WEETABIX - ALPEN BARS
DOUWE EGBERTS - INSTANT COFFEE
DOUWE EGBERTS - PURE GOLD
INSTANT
NESCAFE - COFFEE RGE
WEETABIX - ALPEN CEREAL
NESCAFE - INTENSE AROMA COLLN
WEETABIX - BITESIZE WHOLEGRAIN
DR STUARTS - TEAS
ELLAS KITCHEN - ORGANIC PASTA
SAUCE
NESCAFE - ORIGINAL
WEETABIX - CEREAL
NESCAFE GOLD BLEND
WEETABIX - MINIS
ELLAS KITCHEN - SMOOTHIE FRUITS
NESTLE - SHREDDED WHEAT BITESIZE
WEETABIX - OATIBIX BITESIZE CEREAL
EVIAN WATER
NESTLE - SHREDDED WHEAT CEREAL
WEETABIX - OATY BARS RGE
FEEL GOOD DRINKS CO - RGE
NETTO - PRINCES CHOPPED TOMATOES
WEETABIX READY BREK
FINDUS - PASTA MEALS
NEW YORK BAGELS
FLAHAVANS N IRE - PORRIDGE OATS
NEW YORK BAKERY - BAGELS
FLAHAVENS PORRIDGE
NOORJAHAN - BASMATI RICE
WEETABIX WEET-OS
WELSH LAMB & BEEF PROMOTIONS BEEF
WESTMILL FOODS - HABIB BASMATI
RICE
FLORETTE - CRISPY SALAD
WILSONS COUNTRY - GDN POTATOES
FYFFES BANANAS
NUTRICIA - APTAMIL MILK
OCEAN SPRAY - CRANBERRY JUICE
RANGE
GALAXY - PROBIOTIC DRINK
OMSCO ORGANIC MILK - PROD RGE
WRIGLEY - EXTRA CHEWING GUM
GATORADE
OXO - CONCENTRATED LIQUID STOCK
WRIGLEY - ORBIT COMPLETE
GOOD EARTH - ORGANIC TEA
PEPSI MAX
YOPLAIT - FRUBES LTD EDITION
GREEN GIANT - SOUP RGE
PG TIPS
YOPLAIT - MIXED SEEDS YOGHURT RGE
GREEN GIANT - SWEET CORN
GREGGS BAKERS - OVAL BITES
SANDWHIC
POT NOODLE CO - POT NOODLE RGE
YOPLAIT - PETITS FILOUS
POWERADE
YOPLAIT - PETITS FILOUS FRUBES
HAPPY EGG CO - FREE RGE EGGS
QUAKER - OATSO SIMPLE
YOPLAIT - WILDLIFE FROMAGE FRAIS
66
TYPHOO TEA
WRIGLEY - 5 CHEWING GUM RGE
HFSS advertising restrictions – final review
HEINZ - BEANZ SNAP POTS
QUAKER OATS - PAW RIDGE
YOUNGS - CHIP SHOP FISH FILLET
HEINZ BAKED BEANS
QUAL MEAT SCOT - SCOTCH LAMB
YOUNGS - NATURALLY DELICIOUS FISH
HOVIS
QUORN - MINCE
Note: Brands in bold denote those wholly certified as non-HFSS or a mix of certified and estimated
non-HFSS. Brands not in bold are wholly estimated to be non-HFSS.
*McDonald’s commercials which are certified as non-HFSS have been included in this definition
Figure A10: 2009 HFSS proxy – Brands assessed as HFSS
HFSS brands
AERO - BUBBLES
JORDANS - COUNTRY CRISP CEREAL
NESTLES MILKY BAR
AERO - CHOCOLATE BAR
KAVLI PRIMULA CHEESE
OAKHOUSE FOODS - FROZEN MEAL
AFTER EIGHT - CHOLOCATE MINTS
KELLOGGS - BRAN FLAKES
OCEAN SPRAY - CRANBERRY JUICE
ALPRO - SOYA RGE
OLD EL PASO - CRISPY CHICKEN FAJITA
AMBROSIA - CRUMBLE PUDS RGE
KELLOGGS - CEREAL RANGE
KELLOGGS - COCO POPS MOONS &
STARS
AMBROSIA - JELLY PUDS
KELLOGGS - CRUNCHY NUT BITES
OLD EL PASO - FAJITA DINNER KIT
ANCHOR BUTTER
KELLOGGS - NUTRI GRAIN BAR
OLD EL PASO - STAND N STUFF TACO KI
ARLA FOODS - LURPAK BUTTER RGE
KELLOGGS - NUTRI GRAIN ELEVENSES
OLD JAMAICA - GINGER BEER
ARLA FOODS - LURPAK SPREADABLE
KELLOGGS - RICE KRISPIES
ORMO BREAD
ASDA - CHOCOLATES
KELLOGGS - RICE KRISPIES SQUARES
PAKEEZA DAIRIES - DAIRY PROD RGE
ASDA - CHRISTMAS PUDDING
KELLOGGS - SPEC K CEREAL
PAPA JOHNS - PIZZA RESTR CHAIN
ASDA - CRISPS RGE
KELLOGGS - SPEC K CEREAL RGE
PATAKS INDIAN CUSINE
ASDA - DRINKS RGE
KELLOGGS - SPEC K FRUIT & NUT CLUST
PEPERAMI - BBQ PEPERAMI
ASDA - EASTER EGGS
KELLOGGS - SPEC K MINI BREAKS
PERFETTI VAN MELLE - FRUIT TELLA
ASDA - EXTRA SPEC CHOC RASP BOMB
KELLOGGS - SPEC K OATS & HONEY
PHILEAS FOGG
ASDA - EXTRA SPEC MINCE PIES
KELLOGGS - SPECIAL K BLISS CEREAL
PILGRIMS CHOICE EXTRA MATURE
ASDA - FROZEN FOOD RGE
KELLOGGS CEREAL BARS
PIZZA HUT - RESTR CHAIN
ASDA - HELLMANNS MAYONNAISE
KELLOGGS COCO POPS
PIZZA RISTORANTE
ASDA - ICE CREAM & LOLLIES
KELLOGGS COCO POPS COCO ROCKS
POOJA - FOOD RGE
ASDA - MEAT RGE
KELLOGGS CORN FLAKES
POOLES WIGAN - PIES RGE
ASDA - PARTY FOOD RGE
KELLOGGS CRUNCHY NUT
PRINGLES - CRISPS
ATKINS - DAY BREAK BAR RGE
KELLOGGS CRUNCHY NUT CLUSTERS
QUAKER SNACK A JACKS
BAHLSEN - CHOCO LEIBNIZ BISCUITS
KELLOGGS FROSTIES
QUICK ENERGY - DRINK
BARRS IRN BRU
KELLOGGS SPECIAL K CEREAL BAR
RED BULL
BATCHELORS BEANS
RELENTLESS - ENERGY DRINK
BENECOL - FOOD RGE
KELLOGGS SPECIAL K RED BERRIES
KELLOGSS - RICE
KRISPIES/CORNFLAKES
BERTOLLI - SPREAD
KELLYS - CLOTTED CREAM ICE CREAM
RIBENA - DRINKS RANGE
BETTY CROCKER CAKE MIX
KERRY EASI SINGLES
RICHMOND SAUSAGES
BIKANO FOODS - PROD RGE
KERRY FDS LOW LOW/SP
ROBINSONS - BE NAT
BIRDS EYE - PROD RGE
KERRY FOODS - DENNYS SLICED MEATS
ROBINSONS - CORDIALS RGE
BIRDS EYE - SALMON FISH FINGERS
KERRY FOODS - GOLD MEDAL MEAT
ROBINSONS - JUICE RGE
BIRDS EYE STEAKHOUSE
KERRY FOODS - LOW LOW CHEESE
ROOK & SONS BUTCHERS
BISTO
KERRYGOLD BUTTER
ROWN/QUAL STREET
BLITZ - ENERGIZER SHOTS
KETTLE FOODS - KETTLE CHIPS
ROWNTREES - RANDOMS
BOURSIN CHEESE
KFC KENTUCKY FRIED CHICKEN - RESTR
ROYAL SWEETS - INDIAN SWEETS
BRAND POWER - JUS ROL PASTRY
KILMEADEN - CHEESE
RUBICON - WATERMELON JUICE
BRAND POWER - SCHWARTZ
FLAVOURFUL
KINGSBURY BUTCHER - BUTCHER
RUBICON EXOTIC - MANGO JUICE DRINK
BRITVIC - DRENCH WATER
KITKAT - CHOCOLATE BAR
RUSTLERS - MICROWAVE FOOD RGE
BRITVIC J20
KITKAT - CHUNKY CARAMEL BAR
RYVITA - PROD RGE
BURGER KING - RESTR CHAIN
KITKAT - SENSES
S&S HALAL MEATS - GROCERS
BURN - ENERGY DRINK
KNORR - SOUP RANGE
SACLA - CLASSIC PESTO
C&B - BRANSTON RELISH RGE
KNORR - STOCK POT BEEF
SAINSBURYS - BACON
OLD EL PASO - ENCHILADAS
RELENTLESS - ENERGY SHOT
67
HFSS advertising restrictions – final review
CADBURY - CHOCOLATE BAR RGE
KNORR - STOCK POT RGE
CADBURY - CLUSTERS
KOOL CAKES - BAKERY
SAINSBURYS - BEEF
SAINSBURYS - BEN & JERRYS ICE
CREAM
CADBURY - CREME EGG
KP HULA HOOPS
SAINSBURYS - BISCUITS
CADBURY - CREME EGG TWISTED
KP REAL MCCOYS
CADBURY - DIGESTIVES
KRAFT - DAIRYLEA CHEDDAR SLICES
SAINSBURYS - BRIT SWEETCORN
SAINSBURYS - BUTCHERS CHOICE
SAUSAG
CADBURY CRUNCHIE
KRAFT - DAIRYLEA DUNKERS
SAINSBURYS - CARTE DOR RGE
CADBURY DAIRY MILK
KRAFT - DAIRYLEA DUNKERS FROMAGE
SAINSBURYS - CEREAL RGE
CADBURY WISPA
KRAFT - DAIRYLEA DUNKERS RITZ
SAINSBURYS - EASTER EGG RGE
CAMPBELLS - GATEAUX
KRAFT - DAIRYLEA TRIANGLES
SAINSBURYS - FROZEN FOOD RGE
CAMPBELLS OXO CUBES
CANTRELL & COCHRANE - CLUB
ENERGISE
KRAFT - MIKADO BISCUIT STICKS
SAINSBURYS - FUN SIZE CHOC PACKS
KRAFT - PHILADELPHIA CHEESE
SAINSBURYS - HOT CROSS BUNS
CATHEDRAL CITY - CHEDDAR CHEESE
KRAFT - PHILADELPHIA LIGHT BASIL
SAINSBURYS - KELLOGGS COCO POPS
CATHEDRAL CITY - LIGHTER CHEESE
CEREAL PART - WHOLEGRAIN
AWARENESS
KRAFT - PHILADELPHIA LIGHT CHIVES
SAINSBURYS - LAMB
KRAFT LIGHT PHILI
SAINSBURYS - MEAT
CHARLEVILLE CHEESE
KRAFT PHILADELPHIA GARLIC & HERB
SAINSBURYS - MINCE PIES
CLOVER
KRAFT PHILADELPHIA SPLENDIPS
SAINSBURYS - NESTLE CEREAL RGE
COCA COLA - COKE RGE
SAINSBURYS - NESTLE CHEERIOS
COCA COLA - DRINKS RGE
KWALITY FOODS - FOOD RGE
LACTALIS - PRESIDENT EMMENTAL
CHEES
COCA COLA - ORIGINAL COKE
LAUGHING COW - GIGGLES CHEESE
SAINSBURYS - PEPSI
COOKSTOWN MEATS
LAUGHING COW - PROD RGE
SAINSBURYS - QUAL STREET
COOP - BEEF
LE GRUYERE - EURO CURLING CHAMPS
SAINSBURYS - RUMP STEAK
COOP - COCA COLA RGE
LEERDAMMER CHEESE
SAINSBURYS - SIRLOIN STEAK
COOP - GAMMON
LIDL - ALFREDO PIZZAS
SAINSBURYS - TASTE DIFF MINCE
COUNTRY LIFE - BUTTER RGE
LIDL - BACON RGE
SAINSBURYS - TASTE DIFF PORK
COUNTRY LIFE - ENGLISH BUTTER
LIDL - FROZEN FOOD RGE
SAINSBURYS - WALKERS CRISPS
COVENT GARDEN SOUP
LIDL - GOODY MUESLI
SAINSBURYS PORK SAUS
COW & GATE - OLVARIT RANGE
LIDL - READY MEALS RGE
SCHWAN - CHICAGO TOWN DEEP DISH
COW & GATE - PROD RGE
LINDT - EXCELLENCE CHOCOLATE RGE
DAIRY COUN N IRE
LINDT - GOLD BUNNY
SCHWAN - CHICAGO TOWN PIZZA
SCHWAN - CHICAGO TOWN TAKEAWAY
PIZZ
DAIRY CREST - CLOVER LIGHTER
LINDT - LINDOR CHOCOLATE
SCHWEPPES - GINGER ALE
DAIRY GOLD
LINDT CHOCOLATE
SCHWEPPES - INDIAN TONIC WATER
DAIRYGOLD - BACON
LO SALT
SCHWEPPES - TONIC
DAIRYGOLD - GALTEE MEATS
LOYD GROSSMAN - SAUCE RGE
SHANA - ETHNIC FOOD PROD RGE
DAIRYGOLD - SPREAD
LUCOZADE - DRINK
SHARWOODS - BIRYANI SAUCE RGE
DALE FARM
LUCOZADE - SPORT
SHARWOODS - SAUCE RGE
DANONE VITALINEA
LUCOZADE ENERGY
SHAZAN FOODS - PROD RGE
DENNY IRE - BACON
LURPAK - SPREADABLE UNSALTED
SIMON HOWIE - BUTCHERS
DENNY IRE - MEAT RGE
M&S - INDIAN FOOD RGE
SNICKERS - BAR
DENNYS - COOKED MEATS
M&S - PARTY FOOD
SOMERFIELD - BACON
DENNYS - SAUSAGES
MACKIES ICE CREAM
SOMERFIELD - CADBURY ROSES
DIET CHEF - READY MEALS
MAINE MINERAL WATER COMPANY
SOMERFIELD - CATHEDRAL CITY
DOMINOS PIZZA - RESTR CHAIN
MALTESERS - SWEETS
SOMERFIELD - COCA COLA RGE
DON CARLOS OLIVE OIL
MARMITE - SQUEEZE ME SPREAD
SOMERFIELD - CRUMBED HAM
DONEGAL CATCH - SEAFOOD RGE
MARS - CELEBRATIONS
DR OETKER - HOME CAKE BAKING RGE
MARS - CHOCOLATE DRINKS RGE
SOMERFIELD - DANEPAK BACON
SOMERFIELD - GOLDEN WONDER
CRISPS
DR OETKER - TARTE CAKE MIXES
SOMERFIELD - GOODFELLAS PIZZA
DR PEPPER
MARS - CHOCOLATE RGE
MARS - GOURMET HOT CHOCOLATE
RGE
ELEPHANT CHAPATI FLR
MARS - M&MS
SOMERFIELD - LURPAK
ERIN FOODS - SOUP
MARS - MARS BAR
SOMERFIELD - MCVITIES DIGESTIVES
FANTA - DRINK
MARS - PLANETS
SOMERFIELD - MCVITIES VICTORIA BISC
68
SAINSBURYS - PARTY FOOD
SOMERFIELD - HONEY ROAST HAM
HFSS advertising restrictions – final review
FANTA - ORANGE
MARS - PROD RGE
SOMERFIELD - NESTLE DAIRY BOX
FARMFOODS - FROZEN FOOD RANGE
MARYLAND - CHOC CHIP COOKIES
SOMERFIELD - NESTLE QUAL STREET
FERRERO - KINDER BUENO
MASH DIRECT - PROD RGE
MATTESSONS - FRIDGE RAIDERS
CHICKEN
SOMERFIELD - PEPSI RGE
MATTESSONS - PROD RGE
MATTESSONS - SMOKED PORK
SAUSAGE
MATTHEW WALKER - CHRISTMAS
PUDDING
SOMERFIELD - TERRYS ALL GOLD CHOC
SOMERFIELD - WALKERS SENSATIONS
FIVE ALIVE FRT DRINK
MCDONALDS - RESTR CHAIN*
MCLELLAND SERIOUSLY STRONG
CHEDDAR
FLORA - BUTTERY SPREAD
MCVITIES - BISCUITS RANGE
SPAM - FRITTERS
FLORA - MARGARINE
SPRITE
FLORA - PRO ACTIV RGE
MCVITIES - DIGESTIVE RGE
MCVITIES - GO AHEAD YOGHURT
BREAKS
FLORA - PRO ACTIV SPREAD
MCVITIES - MINI CHOCOLATE DIGESTIVE
STARBURST - SWEETS
FOOD MASTERS - GIA GARLIC PUREE
MCVITIES GO AHEAD
STRATHROY - FRESH CREAM
FOX'S BISCUITS
MENTOS - PURE FRESH GUM
SUBWAY SANDWICH SHOP
FOX'S BISCUITS ROCKY
MI WADI
SUNCREST - FRUIT DRINKS RGE
FOXS - GOLDEN CRUNCH BISCUITS
MIGHTY SPICE CO - SPICE RGE
SUNSWEET PRUNES
FRUITFIELD CHEF KETCHUP
MILKY WAY - CONFICTIONERY
GALAXY - BOOK CLUB
MILLIONS
SURYA FOODS - PROD RGE
SUSSEX FARMHOUSE MEALS DELIVERY
GALAXY - CHOCOLATE
MINI BABYBEL - CHEESE
TABASCO
GALAXY - MINSTRELS CHOCOLATES
MINI CHEDDARS
TERRYS CHOC ORANGE
GALBANI - SANTA LUCIA MAXI MOZZAREL
MISS MILLIES
TESCO - ADVENT CALENDARS
GALTEE PROD RGE
MISSION FOODS - FOOD RGE
TESCO - CHRISTMAS PUDDING
GEN MILLS - WANCHAI FERRY RECIPE KI
MORRISONS - BEN & JERRYS ICE CREAM
TESCO - FROZEN FOOD RGE
GINSTERS - CORNISH PASTY
MORRISONS - BRANSTON BAKED BEANS
GINSTERS - PIES RGE
MORRISONS - BRIT LAMB CHOPS
TESCO - PREPARED PARTY FOOD RGE
TESCO - THORNTONS CLASSIC
CHOCOLATE
GIOVANNI RANA - PASTA RGE
MORRISONS - BRIT PORK
TESCO EASTER EGGS
GLANBIA - PETIT FILOUS YOGHURT
MORRISONS - BRIT RUMP STEAK
MORRISONS - CADBURY ASSORTED
BISCUI
TGI FRIDAYS
MORRISONS - CADBURY ROSES
MORRISONS - CADBURY SELECTION
BOX
MORRISONS - CADBURY TREAT SIZE
PACK
TOBLERONE - TOBELLE
FERRERO - KINDER BUENO WHITE
FERRERO - NUTELLA
FERRERO ROCHER CHOC
FERRERO TIC TAC
FILIPPO BERIO
GOLDEN COW BUTTER
GOLDEN VALE - CHEESTRINGS SNACK
GREGGS BAKERS - CHEESE & ONION
PAST
GREGGS BAKERS - CHILLI STEAK LATTIC
GREGGS BAKERS - CHOCOLATE
MUFFINS
SOMERFIELD - PRINGLES
SOMERFIELD - UNSMOKED GAMMON
SOMERFIELD - WALKERS CRISPS
SOUNAS - ETHNIC BREAD RGE
ST.AGUR CHEESE
THORNTONS - CHOCOLATE RGE
TOPPS - JUICY DROP POP
TOPPS - PUSH POP SLIDERZ
MORRISONS - CHICKEN
TOPPS MEGA MOUTH
GREGGS BAKERS - PROD RGE
MORRISONS - CHOCOLATES
TUNNOCKS - CARAMEL LOG
GREGGS BAKERS - SPOOKY RING BUNS
MORRISONS - EASTER EGGS
TUNNOCKS - CARAMEL WAFER
GREGGS BAKERS - STEAK BAKE
MORRISONS - GOODFELLAS PIZZA
TWIX - BAR
GREGGS BAKERS - YUM YUMS
MORRISONS - I CANT BELIEVE ITS NOT
UNCLE BENS - COOKING SAUCES
GUYLIAN CHOCOLATES
MORRISONS - MCVITIES BISCUITS
UNCLE BENS - EXPRESS RICE
HAAGEN DAZS - ICE CREAM
MORRISONS - MCVITIES JAFFA CAKES
UNCLE BENS - INDIAN SAUCES
HAAGEN DAZS - ICE CREAM SMOOTHIE
MORRISONS - MEAT RANGE
UNCLE BENS - ORIENTAL SAUCES
HALF POUNDERS - CONF RGE
MORRISONS - MR KIPLING MINCE PIES
UNCLE BENS - RISOTTO
HARIBO - SMALL PACKET SWEET RGE
UNCLE BENS - SAUCE & RICE
HARIBO - STARMIX
MORRISONS - MULLER RGE
MORRISONS - PHILEAS FOGG SNACK
RGE
HAZELBROOK FARM - ICE CREAM
MORRISONS - PORK RGE
UNCLE BENS - WOK RICE
HEINZ
MORRISONS - PUFF PASTRY MINCE PIES
UNILEVER - SAT FAT NATION DEBATE
HEINZ SALAD CREAM
MORRISONS - ROBINSONS DRINKS RGE
VB WHOLESALE - CONFECTIONERY
HEINZ TOMATO KETCHUP
MORRISONS - WALKERS CRISPS
VIMTO CORDIAL
HELLMANNS - DRESSINGS RGE
MORRISONS PARTY
HELLMANNS - LIGHT MAYONNAISE
MR KIPLING
WALKERS - DORITOS
WALKERS - DORITOS CORN CHIPS &
DIPS
UNCLE BENS - STIR FRY RGE
69
HFSS advertising restrictions – final review
HELLMANNS - REAL MAYONNAISE
HONEY MONSTER - HARVEST CHEWEEE
BAR
MULLER - CORNER YOGURT RGE
WALKERS - RED SKY CRISPS RGE
MULLER - FRUIT CORNER YOGHURT
WALKERS - SENSATIONS CRISPS RGE
HORMEL FOODS SPAM
MULLER MASTERBRAND
HOTEL CHOCOLAT - PROD RGE
NABISCO - OREO COOKIES
I CANT BELIEVE/BUTTR
NAT CONFECTIONERY CO - SWEET RGE
WALKERS CRISPS
WALLS - CARTE DOR CARAMEL
CINNAMON
WALLS - MAGNUM BOXED TEMPTATION
RGE
ICELAND - FROZEN DESSERT RGE
NATURE VALLEY - CRUNCHY GRANOLA
WALLS - MAGNUM MINI
ICELAND - ICE CREAM
NESTLE - CEREAL RGE
WALLS - SAUSAGE RGE
ICELAND - PARTY FOODS
NESTLE - HONEY OATS & MORE CEREAL
WALLS CARTE D'OR
ICELAND - PIZZA
NESTLE - OAT CHEERIOS
ICELAND - PLATTERS RGE
NESTLE - OATS & MORE RGE
WELCHS - PURPLE GRAPE JUICE
WENSLEYDALE DAIRY PROD - CHEESE
RGE
ICELAND - PRAWNS
NESTLE - RAISIN OATS & MORE CEREAL
ICELAND - QUARTER POUND
NESTLE - SHREDDIES CEREAL
WYKE FARMS - CHEDDAR CHEESE RGE
WYKE FARMS - JUST DELICIOUS XM
CHDR
ICELAND - READY MEAL RGE
NESTLE - WHOLE GRAIN CEREAL RGE
YAKULT YOGHURT
IRWINS BAKERY
NESTLE CHEERIOS
YOPLAIT - PROD RGE
JACOBS CREAM CRACKER
*McDonald’s commercials which are certified as non-HFSS have been excluded from this definition
Products of appeal to children
A4.23
Given that not all food and drink advertising, whether for HFSS or non-HFSS
products, is likely to be targeted at children and in the light of concerns that HFSS
advertising makes a modest contribution to forming children’s food preferences, we
also sought to assess how much of the HFSS advertising that they saw was for
‘brands’ likely to appeal to them.
A4.24
Clearly, any such assessment must be subjective, and can only be regarded as
indicative. Nevertheless, we considered that it would be helpful to understand in
broad terms the balance between HFSS adverts likely to appeal to both children
and adults and those likely to appeal to adults only. It is difficult to make similar
judgements about adverts only likely to appeal to children as adults may be as fond
of particular brands, such as Kelloggs Coco Pops or Mars M&Ms, as children.
A4.25
Taking the ‘brands’ classified as HFSS or non-HFSS (as listed in Figures A9 & A10
above) we assessed each ‘brand’ label to make a judgement on whether the
products were likely to appeal to all audiences or adults only. The classification of
these ‘brands’ is listed in Figures A11 and A12.
Figure A11: HFSS brands (based on the 2009 HFSS proxy) assessed as likely to
appeal to all audiences
HFSS brands of appeal to all
AERO - BUBBLES
KELLOGGS - CRUNCHY NUT BITES
NESTLE - RAISIN OATS & MORE CEREAL
AERO - CHOCOLATE BAR
KELLOGGS - NUTRI GRAIN BAR
NESTLE - SHREDDIES CEREAL
AFTER EIGHT - CHOLOCATE MINTS
KELLOGGS - NUTRI GRAIN ELEVENSES
NESTLE - WHOLE GRAIN CEREAL RGE
AMBROSIA - CRUMBLE PUDS RGE
KELLOGGS - RICE KRISPIES
NESTLE CHEERIOS
AMBROSIA - JELLY PUDS
KELLOGGS - RICE KRISPIES SQUARES
NESTLES MILKY BAR
ASDA - CHOCOLATES
KELLOGGS CEREAL BARS
OAKHOUSE FOODS - FROZEN MEAL
ASDA - CHRISTMAS PUDDING
KELLOGGS COCO POPS
OCEAN SPRAY - CRANBERRY JUICE
ASDA - CRISPS RGE
KELLOGGS COCO POPS COCO ROCKS
OLD JAMAICA - GINGER BEER
ASDA - DRINKS RGE
KELLOGGS CORN FLAKES
PAKEEZA DAIRIES - DAIRY PROD RGE
ASDA - EASTER EGGS
KELLOGGS CRUNCHY NUT
PAPA JOHNS - PIZZA RESTR CHAIN
70
HFSS advertising restrictions – final review
ASDA - EXTRA SPEC CHOC RASP BOMB
KELLOGGS CRUNCHY NUT CLUSTERS
PEPERAMI - BBQ PEPERAMI
ASDA - EXTRA SPEC MINCE PIES
KELLOGGS FROSTIES
PERFETTI VAN MELLE - FRUIT TELLA
ASDA - FROZEN FOOD RGE
KELLYS - CLOTTED CREAM ICE CREAM
PHILEAS FOGG
ASDA - ICE CREAM & LOLLIES
KERRY EASI SINGLES
PIZZA HUT - RESTR CHAIN
ASDA - PARTY FOOD RGE
KETTLE FOODS - KETTLE CHIPS
PIZZA RISTORANTE
ATKINS - DAY BREAK BAR RGE
KFC KENTUCKY FRIED CHICKEN - RESTR
PRINGLES - CRISPS
BAHLSEN - CHOCO LEIBNIZ BISCUITS
KITKAT - CHOCOLATE BAR
QUICK ENERGY - DRINK
BARRS IRN BRU
KITKAT - CHUNKY CARAMEL BAR
RED BULL
BATCHELORS BEANS
KITKAT - SENSES
RELENTLESS - ENERGY DRINK
BETTY CROCKER CAKE MIX
KOOL CAKES - BAKERY
RELENTLESS - ENERGY SHOT
BIKANO FOODS - PROD RGE
KP HULA HOOPS
RIBENA - DRINKS RANGE
BIRDS EYE - PROD RGE
KP REAL MCCOYS
RICHMOND SAUSAGES
BIRDS EYE - SALMON FISH FINGERS
KRAFT - DAIRYLEA CHEDDAR SLICES
ROBINSONS - BE NAT
BIRDS EYE STEAKHOUSE
KRAFT - DAIRYLEA DUNKERS
ROBINSONS - CORDIALS RGE
BLITZ - ENERGIZER SHOTS
KRAFT - DAIRYLEA DUNKERS FROMAGE
ROBINSONS - JUICE RGE
BRITVIC - DRENCH WATER
KRAFT - DAIRYLEA DUNKERS RITZ
ROWNTREES - RANDOMS
BRITVIC J20
KRAFT - DAIRYLEA TRIANGLES
ROYAL SWEETS - INDIAN SWEETS
BURGER KING - RESTR CHAIN
KRAFT - MIKADO BISCUIT STICKS
RUBICON - WATERMELON JUICE
BURN - ENERGY DRINK
KWALITY FOODS - FOOD RGE
RUBICON EXOTIC - MANGO JUICE DRINK
CADBURY - CHOCOLATE BAR RGE
LAUGHING COW - GIGGLES CHEESE
RUSTLERS - MICROWAVE FOOD RGE
CADBURY - CLUSTERS
LAUGHING COW - PROD RGE
SAINSBURYS - BEN & JERRYS ICE CREAM
CADBURY - CREME EGG
LIDL - ALFREDO PIZZAS
CADBURY - CREME EGG TWISTED
LIDL - FROZEN FOOD RGE
SAINSBURYS - BISCUITS
SAINSBURYS - BUTCHERS CHOICE
SAUSAG
CADBURY - DIGESTIVES
LIDL - READY MEALS RGE
SAINSBURYS - CARTE DOR RGE
CADBURY CRUNCHIE
LINDT - EXCELLENCE CHOCOLATE RGE
SAINSBURYS - CEREAL RGE
CADBURY DAIRY MILK
LINDT - GOLD BUNNY
SAINSBURYS - EASTER EGG RGE
CADBURY WISPA
LINDT - LINDOR CHOCOLATE
SAINSBURYS - FROZEN FOOD RGE
CAMPBELLS - GATEAUX
LINDT CHOCOLATE
SAINSBURYS - FUN SIZE CHOC PACKS
CANTRELL & COCHRANE - CLUB ENERGISE
CEREAL PART - WHOLEGRAIN
AWARENESS
LUCOZADE - DRINK
SAINSBURYS - HOT CROSS BUNS
LUCOZADE - SPORT
SAINSBURYS - KELLOGGS COCO POPS
COCA COLA - COKE RGE
LUCOZADE ENERGY
SAINSBURYS - MINCE PIES
COCA COLA - DRINKS RGE
M&S - INDIAN FOOD RGE
SAINSBURYS - NESTLE CEREAL RGE
COCA COLA - ORIGINAL COKE
M&S - PARTY FOOD
SAINSBURYS - NESTLE CHEERIOS
COOP - COCA COLA RGE
MACKIES ICE CREAM
SAINSBURYS - PARTY FOOD
DENNYS - SAUSAGES
MALTESERS - SWEETS
SAINSBURYS - PEPSI
DOMINOS PIZZA - RESTR CHAIN
MARMITE - SQUEEZE ME SPREAD
SAINSBURYS - QUAL STREET
DR OETKER - HOME CAKE BAKING RGE
MARS - CELEBRATIONS
SAINSBURYS - WALKERS CRISPS
DR OETKER - TARTE CAKE MIXES
MARS - CHOCOLATE DRINKS RGE
SAINSBURYS PORK SAUS
DR PEPPER
MARS - CHOCOLATE RGE
SCHWAN - CHICAGO TOWN DEEP DISH
FANTA - DRINK
MARS - GOURMET HOT CHOCOLATE RGE
FANTA - ORANGE
MARS - M&MS
SCHWAN - CHICAGO TOWN PIZZA
SCHWAN - CHICAGO TOWN TAKEAWAY
PIZZ
FARMFOODS - FROZEN FOOD RANGE
MARS - MARS BAR
SCHWEPPES - GINGER ALE
FERRERO - KINDER BUENO
MARS - PLANETS
SNICKERS - BAR
FERRERO - KINDER BUENO WHITE
MARS - PROD RGE
SOMERFIELD - CADBURY ROSES
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HFSS advertising restrictions – final review
FERRERO - NUTELLA
MARYLAND - CHOC CHIP COOKIES
SOMERFIELD - COCA COLA RGE
FERRERO ROCHER CHOC
MASH DIRECT - PROD RGE
SOMERFIELD - GOLDEN WONDER CRISPS
FERRERO TIC TAC
SOMERFIELD - GOODFELLAS PIZZA
FIVE ALIVE FRT DRINK
MATTESSONS - PROD RGE
MATTHEW WALKER - CHRISTMAS
PUDDING
FOXS - GOLDEN CRUNCH BISCUITS
MCDONALDS - RESTR CHAIN*
SOMERFIELD - MCVITIES VICTORIA BISC
FOX'S BISCUITS
MCVITIES - BISCUITS RANGE
SOMERFIELD - NESTLE DAIRY BOX
FOX'S BISCUITS ROCKY
SOMERFIELD - NESTLE QUAL STREET
FRUITFIELD CHEF KETCHUP
MCVITIES - DIGESTIVE RGE
MCVITIES - GO AHEAD YOGHURT
BREAKS
GALAXY - BOOK CLUB
MCVITIES - MINI CHOCOLATE DIGESTIVE
SOMERFIELD - PRINGLES
GALAXY - CHOCOLATE
MCVITIES GO AHEAD
SOMERFIELD - TERRYS ALL GOLD CHOC
GALAXY - MINSTRELS CHOCOLATES
MENTOS - PURE FRESH GUM
SOMERFIELD - WALKERS CRISPS
GALBANI - SANTA LUCIA MAXI MOZZAREL
MI WADI
SOMERFIELD - WALKERS SENSATIONS
GALTEE PROD RGE
MILKY WAY - CONFICTIONERY
SPRITE
GEN MILLS - WANCHAI FERRY RECIPE KI
MILLIONS
STARBURST - SWEETS
GINSTERS - CORNISH PASTY
MINI BABYBEL - CHEESE
SUBWAY SANDWICH SHOP
GINSTERS - PIES RGE
MINI CHEDDARS
SUNCREST - FRUIT DRINKS RGE
GLANBIA - PETIT FILOUS YOGHURT
MISS MILLIES
SURYA FOODS - PROD RGE
GOLDEN VALE - CHEESTRINGS SNACK
MISSION FOODS - FOOD RGE
TERRYS CHOC ORANGE
GREGGS BAKERS - CHEESE & ONION PAST
MORRISONS - BEN & JERRYS ICE CREAM
TESCO - ADVENT CALENDARS
GREGGS BAKERS - CHILLI STEAK LATTIC
TESCO - CHRISTMAS PUDDING
GREGGS BAKERS - CHOCOLATE MUFFINS
MORRISONS - BRANSTON BAKED BEANS
MORRISONS - CADBURY ASSORTED
BISCUI
GREGGS BAKERS - PROD RGE
MORRISONS - CADBURY ROSES
GREGGS BAKERS - SPOOKY RING BUNS
GREGGS BAKERS - STEAK BAKE
MORRISONS - CADBURY SELECTION BOX
MORRISONS - CADBURY TREAT SIZE
PACK
TESCO - PREPARED PARTY FOOD RGE
TESCO - THORNTONS CLASSIC
CHOCOLATE
GREGGS BAKERS - YUM YUMS
MORRISONS - CHOCOLATES
TGI FRIDAYS
GUYLIAN CHOCOLATES
MORRISONS - EASTER EGGS
THORNTONS - CHOCOLATE RGE
HAAGEN DAZS - ICE CREAM
MORRISONS - GOODFELLAS PIZZA
TOBLERONE - TOBELLE
HAAGEN DAZS - ICE CREAM SMOOTHIE
MORRISONS - MCVITIES BISCUITS
TOPPS - JUICY DROP POP
HALF POUNDERS - CONF RGE
MORRISONS - MCVITIES JAFFA CAKES
TOPPS - PUSH POP SLIDERZ
HARIBO - SMALL PACKET SWEET RGE
MORRISONS - MR KIPLING MINCE PIES
TOPPS MEGA MOUTH
HARIBO - STARMIX
TUNNOCKS - CARAMEL LOG
HAZELBROOK FARM - ICE CREAM
MORRISONS - MULLER RGE
MORRISONS - PHILEAS FOGG SNACK
RGE
HEINZ
MORRISONS - PUFF PASTRY MINCE PIES
TWIX - BAR
HEINZ TOMATO KETCHUP
HONEY MONSTER - HARVEST CHEWEEE
BAR
MORRISONS - ROBINSONS DRINKS RGE
VB WHOLESALE - CONFECTIONERY
MORRISONS - WALKERS CRISPS
VIMTO CORDIAL
HOTEL CHOCOLAT - PROD RGE
MORRISONS PARTY
WALKERS - DORITOS
ICELAND - FROZEN DESSERT RGE
MR KIPLING
WALKERS - DORITOS CORN CHIPS & DIPS
ICELAND - ICE CREAM
MULLER - CORNER YOGURT RGE
WALKERS - RED SKY CRISPS RGE
ICELAND - PARTY FOODS
MULLER - FRUIT CORNER YOGHURT
WALKERS - SENSATIONS CRISPS RGE
ICELAND - PIZZA
MULLER MASTERBRAND
ICELAND - QUARTER POUND
NABISCO - OREO COOKIES
ICELAND - READY MEAL RGE
NAT CONFECTIONERY CO - SWEET RGE
WALKERS CRISPS
WALLS - CARTE DOR CARAMEL
CINNAMON
WALLS - MAGNUM BOXED TEMPTATION
RGE
IRWINS BAKERY
NATURE VALLEY - CRUNCHY GRANOLA
WALLS - MAGNUM MINI
KAVLI PRIMULA CHEESE
NESTLE - CEREAL RGE
WALLS - SAUSAGE RGE
72
SOMERFIELD - MCVITIES DIGESTIVES
SOMERFIELD - PEPSI RGE
TESCO - FROZEN FOOD RGE
TESCO EASTER EGGS
TUNNOCKS - CARAMEL WAFER
HFSS advertising restrictions – final review
KELLOGGS - BRAN FLAKES
NESTLE - HONEY OATS & MORE CEREAL
WALLS CARTE D'OR
KELLOGGS - CEREAL RANGE
NESTLE - OAT CHEERIOS
WELCHS - PURPLE GRAPE JUICE
KELLOGSS - RICE KRISPIES/CORNFLAKES
NESTLE - OATS & MORE RGE
YOPLAIT - PROD RGE
KELLOGGS - COCO POPS MOONS & STARS
ROWN/QUAL STREET
*McDonald’s commercials which are certified as non-HFSS have been excluded from this definition
Figure A12: HFSS brands (based on the 2009 HFSS proxy) assessed as likely to
appeal to adults only
HFSS brands of appeal to adults
ALPRO - SOYA RGE
HORMEL FOODS SPAM
ORMO BREAD
ANCHOR BUTTER
ICELAND - PLATTERS RGE
PATAKS INDIAN CUSINE
ARLA FOODS - LURPAK BUTTER RGE
ICELAND - PRAWNS
PILGRIMS CHOICE EXTRA MATURE
ARLA FOODS - LURPAK SPREADABLE
I CANT BELIEVE/BUTTR
POOJA - FOOD RGE
ASDA - HELLMANNS MAYONNAISE
JACOBS CREAM CRACKER
POOLES WIGAN - PIES RGE
ASDA - MEAT RGE
JORDANS - COUNTRY CRISP CEREAL
QUAKER SNACK A JACKS
BENECOL - FOOD RGE
KELLOGGS - SPEC K CEREAL
ROOK & SONS BUTCHERS
BERTOLLI - SPREAD
KELLOGGS - SPEC K CEREAL RGE
RYVITA - PROD RGE
BISTO
KELLOGGS - SPEC K FRUIT & NUT CLUST
S&S HALAL MEATS - GROCERS
BOURSIN CHEESE
KELLOGGS - SPEC K MINI BREAKS
SACLA - CLASSIC PESTO
BRAND POWER - JUS ROL PASTRY
BRAND POWER - SCHWARTZ
FLAVOURFUL
KELLOGGS - SPEC K OATS & HONEY
SAINSBURYS - BACON
KELLOGGS - SPECIAL K BLISS CEREAL
SAINSBURYS - BEEF
C&B - BRANSTON RELISH RGE
KELLOGGS SPECIAL K CEREAL BAR
SAINSBURYS - BRIT SWEETCORN
CAMPBELLS OXO CUBES
KELLOGGS SPECIAL K RED BERRIES
SAINSBURYS - LAMB
CATHEDRAL CITY - CHEDDAR CHEESE
KERRY FOODS - DENNYS SLICED MEATS
SAINSBURYS - MEAT
CATHEDRAL CITY - LIGHTER CHEESE
KERRY FOODS - GOLD MEDAL MEAT
SAINSBURYS - RUMP STEAK
CHARLEVILLE CHEESE
KERRY FOODS - LOW LOW CHEESE
SAINSBURYS - SIRLOIN STEAK
CLOVER
KERRY FDS LOW LOW/SP
SAINSBURYS - TASTE DIFF MINCE
COOKSTOWN MEATS
KERRYGOLD BUTTER
SAINSBURYS - TASTE DIFF PORK
COOP - BEEF
KILMEADEN - CHEESE
SCHWEPPES - INDIAN TONIC WATER
COOP - GAMMON
KINGSBURY BUTCHER - BUTCHER
SCHWEPPES - TONIC
COUNTRY LIFE - BUTTER RGE
KNORR - SOUP RANGE
SHANA - ETHNIC FOOD PROD RGE
COUNTRY LIFE - ENGLISH BUTTER
KNORR - STOCK POT BEEF
SHARWOODS - BIRYANI SAUCE RGE
COVENT GARDEN SOUP
KNORR - STOCK POT RGE
SHARWOODS - SAUCE RGE
COW & GATE - OLVARIT RANGE
KRAFT - PHILADELPHIA CHEESE
SHAZAN FOODS - PROD RGE
COW & GATE - PROD RGE
KRAFT - PHILADELPHIA LIGHT BASIL
SIMON HOWIE - BUTCHERS
DAIRY COUN N IRE
KRAFT - PHILADELPHIA LIGHT CHIVES
SOMERFIELD - BACON
DAIRY CREST - CLOVER LIGHTER
KRAFT LIGHT PHILI
SOMERFIELD - CATHEDRAL CITY
DAIRY GOLD
KRAFT PHILADELPHIA GARLIC & HERB
SOMERFIELD - CRUMBED HAM
DAIRYGOLD - BACON
KRAFT PHILADELPHIA SPLENDIPS
SOMERFIELD - DANEPAK BACON
DAIRYGOLD - GALTEE MEATS
LACTALIS - PRESIDENT EMMENTAL CHEES
SOMERFIELD - HONEY ROAST HAM
DAIRYGOLD - SPREAD
LE GRUYERE - EURO CURLING CHAMPS
SOMERFIELD - LURPAK
DALE FARM
LEERDAMMER CHEESE
SOMERFIELD - UNSMOKED GAMMON
DANONE VITALINEA
LIDL - BACON RGE
SOUNAS - ETHNIC BREAD RGE
DENNY IRE - BACON
LIDL - GOODY MUESLI
SPAM - FRITTERS
DENNY IRE - MEAT RGE
LO SALT
ST.AGUR CHEESE
73
HFSS advertising restrictions – final review
DENNYS - COOKED MEATS
LOYD GROSSMAN - SAUCE RGE
STRATHROY - FRESH CREAM
DIET CHEF - READY MEALS
LURPAK - SPREADABLE UNSALTED
SUNSWEET PRUNES
DON CARLOS OLIVE OIL
MAINE MINERAL WATER COMPANY
SUSSEX FARMHOUSE MEALS - DELIVERY
DONEGAL CATCH - SEAFOOD RGE
MATTESSONS - FRIDGE RAIDERS CHICKEN
TABASCO
ELEPHANT CHAPATI FLR
UNCLE BENS - COOKING SAUCES
ERIN FOODS - SOUP
MATTESSONS - SMOKED PORK SAUSAGE
MCLELLAND SERIOUSLY STRONG
CHEDDAR
FILIPPO BERIO
MIGHTY SPICE CO - SPICE RGE
UNCLE BENS - INDIAN SAUCES
FLORA - BUTTERY SPREAD
MORRISONS - BRIT LAMB CHOPS
UNCLE BENS - ORIENTAL SAUCES
FLORA - MARGARINE
MORRISONS - BRIT PORK
UNCLE BENS - RISOTTO
FLORA - PRO ACTIV RGE
MORRISONS - BRIT RUMP STEAK
UNCLE BENS - SAUCE & RICE
FLORA - PRO ACTIV SPREAD
MORRISONS - CHICKEN
UNCLE BENS - STIR FRY RGE
FOOD MASTERS - GIA GARLIC PUREE
MORRISONS - I CANT BELIEVE ITS NOT
UNCLE BENS - WOK RICE
GIOVANNI RANA - PASTA RGE
MORRISONS - MEAT RANGE
GOLDEN COW BUTTER
MORRISONS - PORK RGE
UNILEVER - SAT FAT NATION DEBATE
WENSLEYDALE DAIRY PROD - CHEESE
RGE
HEINZ SALAD CREAM
OLD EL PASO - CRISPY CHICKEN FAJITA
WYKE FARMS - CHEDDAR CHEESE RGE
HELLMANNS - DRESSINGS RGE
OLD EL PASO - ENCHILADAS
WYKE FARMS - JUST DELICIOUS XM CHDR
HELLMANNS - LIGHT MAYONNAISE
OLD EL PASO - FAJITA DINNER KIT
YAKULT YOGHURT
HELLMANNS - REAL MAYONNAISE
OLD EL PASO - STAND N STUFF TACO KI
UNCLE BENS - EXPRESS RICE
Figure A13: Non-HFSS brands (based on the 2009 HFSS proxy) likely to appeal to all
audiences
Non-HFSS brands of appeal to all
AUNT BESSIES - PROD RGE
MCCAIN - RUSTIC OVEN CHIPS
BATCHELORS SQUEEZ
MCCAIN - SMILES
TESCO - HOT CROSS BUNS
TREBOR BASSETT - EXTRA STRONG
GUM
BENECOL - FRUIT & DAIRY SMOOTHIE
MCCAIN - SWEET POTATO
TRIDENT - SUGARFREE GUM
BIO SYNERGY - SKINNY WATER
MCCAIN - WEDGES
TROPICANA
BIRDS EYE - OMEGA 3 FISH FINGERS
MCCAIN HOME FRIES
WEETABIX - ALPEN BARS
BIRDS EYE - REGGAE REGGAE CHICKEN C
MCCAIN OVEN CHIPS
WEETABIX - BITESIZE WHOLEGRAIN
BRACE'S BAKERY
MCDONALDS - RESTR CHAIN*
WEETABIX - CEREAL
CAPRI-SUN FRT DRINK
MORRISONS - DRINK RGE
WEETABIX - MINIS
COCA COLA - COCA COLA ZERO
MULLER - LITTLE STARS RGE
WEETABIX - OATIBIX BITESIZE CEREAL
COCA COLA - DIET COKE
MULLER - MULLERICE
WEETABIX - OATY BARS RGE
DOLMIO - MY DOLMIO KIDS RGE
MUNCH BUNCH - DOUBLE UP YOGHURT
WEETABIX READY BREK
ELLAS KITCHEN - SMOOTHIE FRUITS
MUNCH BUNCH - YOGHURTS
WEETABIX WEET-OS
FEEL GOOD DRINKS CO - RGE
OCEAN SPRAY - CRANBERRY JUICE RANGE
WRIGLEY - 5 CHEWING GUM RGE
GATORADE
PEPSI MAX
WRIGLEY - EXTRA CHEWING GUM
GREEN GIANT - SWEET CORN
POT NOODLE CO - POT NOODLE RGE
WRIGLEY - ORBIT COMPLETE
GREGGS BAKERS - OVAL BITES SANDWHIC
POWERADE
HEINZ - BEANZ SNAP POTS
RED BULL - SUGARFREE
YOPLAIT - FRUBES LTD EDITION
YOPLAIT - MIXED SEEDS YOGHURT
RGE
HEINZ BAKED BEANS
ROBINSONS - FRUIT SHOOT
YOPLAIT - PETITS FILOUS
INNOCENT - SMOOTHIES
SCHWEPPE OASIS DRINK
YOPLAIT - PETITS FILOUS FRUBES
INNOCENT - SMOOTHIES FOR KIDS
SUNNY DELIGHT
YOPLAIT - WILDLIFE FROMAGE FRAIS
MCCAIN - PROD RGE
SUSO - DRINKS RGE
YOUNGS - CHIP SHOP FISH FILLET
*McDonald’s commercials which are certified as non-HFSS have been included in this definition
74
HFSS advertising restrictions – final review
Figure A14: Non-HFSS brands (based on the 2009 HFSS proxy) likely to appeal to
adults only
Non-HFSS brands of appeal to adults
ALBERT BARTLETT - ROOSTER
POTATOES
GREEN GIANT - SOUP RGE
PG TIPS
ALPRO - SOYA MILK
HAPPY EGG CO - FREE RGE EGGS
QUAKER - OATSO SIMPLE
ALPRO SOYA - LIGHT MILK
HOVIS
QUAKER OATS - PAW RIDGE
ASDA - BREAD RGE
HOVIS - ROLLS RGE
QUAL MEAT SCOT - SCOTCH LAMB
ASDA - FRUIT
HOVIS - SEED SENSATIONS BREAD
QUORN - MINCE
ASDA - RUMP STEAK
ICELAND - FROZEN VEGETABLES
QUORN - PROD RGE
ASDA - TURKEY
ICELAND - KING PRAWN KEBAB SELECTIO
ROOSTER - IRISH POTATOES
AVONMORE SUPERMILK
INNOCENT - VEG POTS
SAINSBURYS - EGGS
BARRYS TEA/GOLD BLEN
ISKLAR - MINERAL WATER
SAINSBURYS - FRESH FRUIT
BARRYS GOLD BLEND TEA
JOHN WEST - NO DRAIN TUNA
SAINSBURYS - GRAPES
BIRDS EYE - FIELD FRESH GDN PEAS
BLUEBERRIES FROM SOUTH BLUEBERRY
JOHN WEST - TINNED TUNA
SAINSBURYS - JERSEY ROYAL POTATOES
KELLOGGS - OPTIVITA
SAINSBURYS - RED LABEL TEA
BRENNANS BREAD
KENCO - INSTANT COFFEE
SAINSBURYS - SALMON
BROOKE BOND PG TIPS
KENCO - PURE RGE
SAINSBURYS - STRAWBERRIES
BUXTON SPRING WATER
KINGSMILL - 50 50 BREAD
SAINSBURYS - TASTE DIFF KING PRAWNS
COOP - BAKING POTATOES
KINGSMILL - GREAT EVERYDAY BREAD
SAINSBURYS - VEG RGE
COOP - CLEMENTINES
KINGSMILL - LITTLE BIG LOAF RGE
SCOTTISH DAIRY MRKTG - MILK
COOP - COX APPLES
KINGSMILL WHOLEMEAL
COOP - FRESH CHICKEN
LACTOFREE - SEMI SKIMMED MILK
SHARWOODS - BOMBAY POTATOES
SHARWOODS - CANTONESE CURRY
SAUCE
COOP - FRESH VEG
LAILA - FLOUR RGE
SHARWOODS - MICROWAVE NOODLES
COOP - HOVIS BREAD
LAVAZZA - ESPRESO COFFEE
SIMPLY FISH
COOP - JOHN WEST WILD RED SALMON
LIDL - FRUIT & VEG
SMA - FOLLOW ON MILK
COOP - NESCAFE ORIG COFFEE
LITTLE DISH - READY MEALS
SMA - PROGRESS MILK
COOP - PG TIPS
LYONS IRELAND - TEA
SMA - TODDLER MILK
COOP - SALMON
MAXWELL HOUSE
SOMERFIELD - BEEF
COOP - WARBURTONS BREAD
COOP - WARBURTONS SLICED WHITE
ROLL
MEAT & LIVESTOCK COMM - MINCE
SOMERFIELD - CHICKEN
MILUPA - APTAMIL FOLLOW ON
SOMERFIELD - COOKED HAM
COW & GATE - BABY BALANCE PORRIDGE
MORRISONS - BREAD RGE
SOMERFIELD - DRY CURED HAM
COW & GATE - BABY BALANCE RGE
MORRISONS - BRIT NEW POTATOES
SOMERFIELD - LEAN STEAK MINCE
COW & GATE - COMP CARE FOLLOW ON
MORRISONS - COD FILLETS
SOMERFIELD - PORK
COW & GATE - COMP CARE GROWING UP
MORRISONS - COX APPLES
SOMERFIELD - POTATOES
CRAVENDALE - MILK
MORRISONS - FRESH FISH RGE
SOMERFIELD - STEAK
DALE FARM - ONE PERCENT MILK
MORRISONS - FRESH SCOT SALMON
SOMERFIELD - STRAWBERRIES
DANONE - ACTIMEL
MORRISONS - FRESH VEGETABLES
SOMERFIELD - TETLEY TEA BAGS
DANONE - ACTIVIA FIBRE YOGHURT RGE
MORRISONS - FRUIT
SOMERFIELD - YOUNGS SALMON FILLETS
DANONE - ACTIVIA INTENSELY CREAMY
MORRISONS - FRUIT & VEG
STARBUCKS COFFEE - COFFEE
DANONE - ACTIVIA YOGURTS RGE
MORRISONS - HADDOCK FILLETS
STRATHMORE - SPRING WATER
DANONE - BIO ACTIVIA YOGHURT
MORRISONS - JERSEY ROYALS
TAYLORS - YORKSHIRE TEA
DANONE DANACOL YOGHURT
MORRISONS - KING PRAWNS
TAYLORS - YORKSHIRE TEA HARD WATER
DANONE DANONINO
MORRISONS - PG TIPS
TETLEY - REDBUSH
DANONE SHAPE YOGURT
MORRISONS - PRINCES RED SALMON
TETLEY GREEN TEA RGE
75
HFSS advertising restrictions – final review
DENNY IRE - HAM
MORRISONS - SALMON FILLETS
TIPPERARY - NATURAL MINERAL WATER
DOLMIO - BOLOGNESE SAUCE
TWININGS - ENGLISH BREAKFAST TEA
DOLMIO - LASAGNE SAUCE RGE
MORRISONS - SCOTCH BEEF
MULLER - CORNER HEALTHY BALANCE
YOG
DOLMIO - SAUCE RANGE
MULLER - MULLER LIGHT YOGHURT
TWININGS - SPECIALITY TEA
DOLMIO - STIR IN SAUCE
NESCAFE - COFFEE RGE
TWININGS - TEA RANGE
DOUWE EGBERTS - INSTANT COFFEE
NESCAFE - INTENSE AROMA COLLN
TWININGS EVERY DAY TEA
DOUWE EGBERTS - PURE GOLD INSTANT
NESCAFE - ORIGINAL
TYPHOO TEA
DR STUARTS - TEAS
NESCAFE GOLD BLEND
UNCLE BENS - BOIL IN A BAG RICE
ELLAS KITCHEN - ORGANIC PASTA SAUCE
NESTLE - SHREDDED WHEAT BITESIZE
VOLVIC
EVIAN WATER
NESTLE - SHREDDED WHEAT CEREAL
WARBURTONS BREAD
FINDUS - PASTA MEALS
NETTO - PRINCES CHOPPED TOMATOES
WARBURTONS CRUMPETS
FLAHAVANS N IRE - PORRIDGE OATS
NEW YORK BAGELS
FLAHAVENS PORRIDGE
NEW YORK BAKERY - BAGELS
WEETABIX - ALPEN CEREAL
WELSH LAMB & BEEF PROMOTIONS –
BEEF
FLORETTE - CRISPY SALAD
NOORJAHAN - BASMATI RICE
WESTMILL FOODS - HABIB BASMATI RICE
FYFFES BANANAS
NUTRICIA - APTAMIL MILK
WILSONS COUNTRY - GDN POTATOES
GALAXY - PROBIOTIC DRINK
OMSCO ORGANIC MILK - PROD RGE
YOUNGS - NATURALLY DELICIOUS FISH
GOOD EARTH - ORGANIC TEA
OXO - CONCENTRATED LIQUID STOCK
76
TWININGS - LADY GREY TEA
HFSS advertising restrictions – final review
Annex 5
5 Changes in children’s exposure to food
and drink advertising
Introduction
A5.1
In considering whether there has been a change in the amount of HFSS food and
drink advertising seen by children between 2005 and 2009 (‘the reference period’),
it is also useful to look at changes that have occurred in child impacts for all ‘food
and drink’ advertising, of which HFSS advertising is a proportion. This enables us to
look at trend data over the time period for the entire food and drinks category. Many
of the trends seen at the food and drink category level are reflected in changes to
HFSS advertising. This measure, referred to as ‘Core Categories’ in documents
between 2004–2007, was used by Ofcom across all its analysis in this area to
understand the entire food and drink market, This was necessary in the absence of
any nutrient profiling measures during the initial stages of this work.
A5.2
This section looks at the following:
a) how much food and drink advertising children are seeing now, as compared to
2005;
b) on which channels/types of channels children are seeing food and drink
advertising now compared with 2005; and
c) what time of day are children seeing food and drink advertising now compared
with 2005.
Data sources
A5.3
This annex covers all ‘food and drink’ advertising and is based on the Nielsen
product categories listed in Annex 4. In brief, these comprise all food and drink
products, including chain (fast food) restaurants, but excluding alcoholic drinks. The
amount of food and drink advertising seen by children is measured in ‘impacts’68.
A5.4
It should also be noted that by definition all ‘food and drink’ advertising includes
both HFSS and non-HFSS products. This means that even after the introduction of
restrictions, food and drink advertising still occurs during airtime when HFSS
advertising is restricted.
Key findings
A5.5
The amount of ‘food and drink’ advertising children are seeing has fallen since
2005, despite a substantial increase in the number of ‘food and drink’ advertising
spots broadcast over the same period (due in large part to an increase in the
number of TV channels). The amount of TV children watch has not changed
significantly.
A5.6
Comparing 2009 to 2005:
68
See definition in section 3.
77
HFSS advertising restrictions – final review
a) children saw 13% less food and drink advertising overall;
b) younger children (4-9 year olds) saw 25% less food and drink advertising and
older children (10-15 year olds) saw 2% less;
c) overall children saw 27% less food and drink advertising on the commercial PSB
channels but 1% more on commercial non-PSBs;
d) during children’s airtime, exposure to food and drink advertising fell 92% on
commercial PSBs (i.e. children’s slots such as Five’s Milkshake) and by 65% on
commercial non-PSBs (i.e. children’s channels such as Nick Jr, and Tiny POP);
e) children saw 14% less food and drink advertising during adult airtime on the
commercial PSB channels. However over the same period exposure to food and
drink advertising during adult airtime on commercial non-PSB channels rose
71%. As a result children saw 17% more food and drink advertising overall in
adult airtime; and
f)
the growth in food and drink advertising impacts during adult airtime on
commercial non-PSB channels was driven by a 279% increase in impacts on
commercial PSB portfolio channels, which reflects children’s increased viewing to
these services over this period (see section 4).
Changes in children’s exposure to food and drink advertising
All Airtime
A5.7
In 2003, the year when the Government called for a change in the nature and
balance of food advertising to children, food and drink advertising accounted for
18.2bn child impacts – 20% of all advertising seen by 4-15 year olds. Impacts have
been in steady decline since then, falling to 13.0bn in 2009. Food and drink
advertising accounted for 13% of the advertising seen by children in 2009, down
from 16% in 2005.
Figure A15: Total television impacts – Children 4-15
Total television advertising impacts: Children 4-15
Impacts
95.5bn
92.8bn
92.4bn
16.2
15.0
14.8
13.0
Impacts (bn)
18.2
96.4bn
97.1bn
13.3
13.0
Food &
Drink
75.3
80.2
80.5
78.0
79.4
85.1
84.1
2003
2004
2005
2006
2007
2008
2009
Source: Nielsen Media
Note: Minor variations due to rounding
78
98.4bn
All other
categories
Share of impacts - %
93.5bn
Share of impacts
93.5bn
96.4bn
95.5bn
92.8bn
92.4bn
98.4bn
97.1bn
20%
17%
16%
16%
14%
14%
13%
81%
83%
84%
84%
86%
87%
87%
2003
2004
2005
2006
2007
2008
2009
HFSS advertising restrictions – final review
Children’s exposure to food and drink advertising in children’s airtime vs adult
airtime.
A5.8
As with the trends observed across HFSS advertising between 2005 and 2009,
exposure to food and drink advertising declined during children’s airtime and on the
commercial PSB channels. However there was an increase in impacts during adult
airtime on the commercial non-PSB channels. These channels accounted for 3.6bn
child impacts in 2005, rising to 6.2bn impacts in 2009.
Figure A16: Food and drink impacts by airtime – Children 4-15
Food & Drink impacts by airtime: Children 4-15
18.2bn
3.2
Adult airtime Commercial non-PSB
channels
16.2bn
15.0bn
14.8bn
3.2
Impacts (bn)
3.6
13.0bn
13.3bn
5.0
5.5
13.0bn
5.0
7.3
6.5
6.2
6.3
5.9
5.7
5.4
5.6
5.4
4.7
3.8
Adult airtime Commercial PSB
channels
Children’s airtime Commercial non-PSB
channels
Children’s airtime Commercial PSB
channels
3.4
2.4
2003
1.7
1.2
0.5
2004
2005
2006
2.2
0.1
2007
2.1
0.1
2008
1.3
0.1
2009
Source: Nielsen Media
Note: Minor variations due to rounding
A5.9
Children’s airtime accounted for 33.5% of all food and drink impacts in 2005; this
figure fell steadily to 10.8% in 2009. Over the same period the share of impacts
represented by the commercial PSB channels (during adult airtime) remained fairly
stable while the commercial non-PSB channels increased their share from 24.2% to
47.4%. As can be seen by comparing Figures A16 and A17, there was an increase
in both the volume and share of impacts across these channels).
Figure A17: Share of food and drink impacts by airtime – Children 4-15
Share of Food & Drink impacts by airtime: Children 4-15
18.2
16.2
15.0
17.4%
19.9%
24.2%
14.8
Share of impacts, %
33.6%
40.0%
13.0
38.5%
13.3
41.7%
13.0
47.4%
39.7%
43.6%
42.0%
41.7%
29.2%
23.0%
2003
10.7%
2004
16.5%
15.5%
8.0%
3.5%
1.0%
2005
2006
2007
0.7%
2008
Children’s airtime –
Commercial non-PSB
channels
Children’s airtime Commercial PSB
channels
25.5%
12.9%
Adult airtime –
Commercial non-PSB
channels
Adult airtime Commercial PSB
channels
40.1%
42.3%
29.6%
Total impacts (bn)
10.1%
0.7%
2009
Source: Nielsen Media
Note: Minor variations due to rounding
79
HFSS advertising restrictions – final review
A5.10
The 13% overall reduction in food and drink impacts was driven by trends during
children’s airtime (down 72%) and the commercial PSB channels (down 14%). The
effect of these reductions was offset, to some extent, by the 71% increase during
adult airtime on commercial non-PSB channels.
A5.11
Over the same period, food and drink impacts for 4-9 year olds fell 25% overall,
from 7.2bn to 5.4bn impacts – this was driven by a 69% decline in children’s airtime.
The 60% increase in exposure to food and drink advertising between 2005 and
2009 on the commercial non-PSB channels led to an overall 11% rise in exposure
for younger children during adult airtime.
A5.12
The exposure of 10-15 year olds to food and drink advertising fell 2% overall
between 2005 and 2009. Although impacts fell 78% during children’s airtime, this
was offset by a 20% rise in adult airtime driven by the increase in impacts on the
commercial non-PSB channels (up 78%).
Children’s exposure to food and drink advertising - by channel groups.
A5.13
Figures A18 and A19 show that similar trends to those observed in our analysis of
children’s viewing habits and their exposure to HFSS advertising are present when
looking at food and drink advertising. The launch of more commercial PSB portfolio
channels and their increased popularity led to a growth in food and drink impacts on
these channels from 0.7bn impacts in 2005 to 2.7bn impacts in 2009 – an increase
of 279%. These channels accounted for 20.8% of food and drink impacts in 2009,
up from 4.8% in 2005.
A5.14
There appears to be some displacement of food and drink impacts from the
commercial PSB channels to the commercial PSB portfolio channels. The total
number of food and drink impacts during adult airtime on the commercial PSB
channels and the commercial PSB portfolio channels increased from 7.1bn in 2005
to 8.2bn in 2009 – a rise of 15%.
Figure A18: Food and drink impacts by channel groups – Children 4-15
Food & Drink impacts by channel groups: Children 4-15
18.2bn
2.5
16.2bn
0.4
0.3
2.4
Impacts (bn)
0.5
0.4
All other commercial nonPSB channels
15.0bn
2.5
0.4
0.7
7.3
6.5
14.8bn
3.5
0.5
1.0
6.3
Music channels
13.0bn
13.3bn
2.9
2.9
0.5
1.6
0.3
2.3
13.0bn
3.0
0.5
5.7
5.6
5.4
4.7
3.8
3.4
2.4
2003
1.7
1.2
0.5
2004
2005
2006
2.2
0.1
2007
2.1
0.1
2008
1.3
0.1
2009
Source: Nielsen Media
Note: Minor variations due to rounding
4 Music added to the ‘PSB portfolio channels’ measure in 2008 – The Hits removed from ‘Music Channels’ in 2008
* Main PSB channels + PSB portfolio channels
80
Adult airtime - Commercial
PSB channels
2.7
5.9
5.4
Commercial PSB portfolio
channels
Children’s airtime Commercial non-PSB
channels
Children’s airtime Commercial PSB channels
HFSS advertising restrictions – final review
Figure A19: Share of food and drink impacts by channel groups – Children 4-15
Share of Food & Drink impacts by channel groups: Children 4-15
13.9%
Share of impacts, %
2.0%
1.5%
40.0%
14.6%
16.9%
2.9%
2.4%
2.5%
4.8%
23.3%
22.4%
21.5%
23.1%
3.3%
6.9%
4.0%
2.6%
3.5%
12.2%
17.5%
40.1%
20.8%
42.3%
39.7%
43.6%
29.6%
42.0%
41.7%
29.2%
25.5%
23.0%
12.9%
2003
10.7%
2004
16.5%
15.5%
8.0%
3.5%
1.0%
2005
2006
2007
0.7%
2008
10.1%
0.7%
2009
All other commercial
non-PSB channels
Music channels
Commercial PSB
portfolio channels
Adult airtime Commercial PSB
channels
Children’s airtime Commercial Non-PSB
channels
Children’s airtime Commercial PSB
channels
Source: Nielsen Media
Note: Minor variations due to rounding
4 Music added to the ‘PSB portfolio channels’ measure in 2008 – The Hits removed from ‘Music Channels’ in 2008
Children’s exposure to food and drink advertising - by time of day.
A5.15
While food and drink impacts fell during children’s airtime there was no significant
increase during any particular daypart in adult airtime – impacts increased across
all dayparts except the 06:00-09:30 slot.
A5.16
Analysis of the share of food and drink impacts by daypart shows that the
proportion of impacts delivered during children’s airtime fell 22.7 percentage points
from 33.5% in 2005 to 10.8% in 2009. Given the restrictions we can assume this
remaining advertising is for non-HFSS products. Over the same period the share of
impacts delivered after 18:00 increased by 15 percentage points from 47.3% to
62.2%. In volume terms the number of impacts delivered after 18:00 increased from
7.1bn impacts to 8.1bn impacts.
81
HFSS advertising restrictions – final review
Figure A20: Food and drink impacts by daypart – Children 4-15
Food & Drink impacts by daypart: Children 4-15
18.2bn
1.0
1.9
16.2bn
0.9
1.8
Impacts (bn)
4.4
2230-close
15.0bn
0.9
14.8bn
1.0
1.8
1.8
4.1
0.8
0.4
0.5
0.7
0.7
7.8
2003
4.4
0.7
0.4
0.5
0.6
0.7
6.5
2004
0.8
0.4
0.5
0.5
0.7
5.0
2005
2100-2230
13.0bn
1.1
13.3bn
1.1
1.9
2.0
4.4
4.6
0.8
0.6
0.6
0.7
0.6
1.0
0.6
0.7
0.7
0.6
2.3
2.2
2007
2008
13.0bn
1.1
1700-1800
2.2
1515-1700
4.6
0.9
0.6
0.6
0.7
0.8
3.9
2006
1800-2100
1230-1515
4.7
1.0
0.6
0.7
0.7
0.5
1.4
0930-1230
0600-0930
Children's airtime
2009
Source: Nielsen Media
Note: Minor variations due to rounding
‘Children’s airtime’ consists of children’s slots on main PSB channels and dedicated children’s channels
Figure A21: Share of food and drink impacts by daypart – Children 4-15
Share of Food & Drink impacts by daypart: Children 4-15
18.2
Share of impacts, %
5.6%
10.5%
24.1%
4.4%
2.2%
2.9%
4.0%
3.6%
42.6%
2003
16.2
5.8%
11.0%
25.2%
4.5%
2.3%
3.1%
4.0%
4.1%
40.0%
2004
15.0
14.8
6.2%
6.5%
11.9%
12.1%
13.0
13.3
8.1%
8.1%
8.8%
15.0%
15.0%
17.2%
Total impacts (bn)
2230-close
2100-2230
1800-2100
29.1%
30.9%
34.0%
5.0%
2.6%
3.4%
3.6%
4.6%
33.5%
2005
5.7%
4.3%
4.1%
4.6%
5.1%
34.3%
6.0%
4.4%
4.8%
5.1%
5.0%
7.2%
4.2%
5.1%
5.1%
4.7%
17.6%
16.2%
2007
2008
26.6%
2006
Source: Nielsen Media
Note: Minor variations due to rounding
‘Children’s airtime’ consists of children’s slots on main PSB channels and dedicated children’s channels
82
13.0
1700-1800
36.2%
1515-1700
1230-1515
7.7%
4.6%
5.3%
5.3%
3.9%
10.8%
2009
0930-1230
0600-0930
Children's airtime
HFSS advertising restrictions – final review
Annex 6
6 Changes in advertising impacts by
different measures
Summary of changes in children’s exposure to advertising
A6.1
The table below summarises the changes in child impacts by age group across the
key measures used in this review (details of each have been set out in Annex 3). In
summary the measures are as follows:
a) 2005 HFSS Proxy vs. 2009 HFSS Proxy – this compares 2005 impacts data
using the 2005 HFSS Proxy definition with 2009 impacts data based on the 2009
HFSS Proxy definition. The 2009 HFSS Proxy definition is based on the
classification of products at a ‘brand’ level as HFSS or non-HFSS and excludes
specific McDonald’s commercials which have been certified as non-HFSS;
b) 2005 HFSS Proxy: 2005 vs. 2009 – this compares 2005 and 2009 data using the
2005 HFSS Proxy definition for both 2005 and 2009. This assumes that certain
Nielsen food and drink categories were wholly comprised of HFSS products,
while others were wholly comprised of non-HFSS products and is therefore
based on excluding specific sub-categories from the food and drink measure; and
c) All food and drink – this compares 2005 and 2009 child impacts for all food and
drink advertising. More detailed analysis of changes in food and drink advertising
can be found in Annex 5.
Figure A22: Summary of changes in advertising impacts by different measures
% change in impacts, 2005 vs. 2009
Airtime
Measure
All airtime
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
Children, by age group
4-15
4-9
10-15
-37
-52
-22
-15
-29
-3
-13
-25
-2
Children’s airtime
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
-100
-74
-72
-1
+17
+17
-100
-72
-69
-8
+11
+11
-100
-78
-78
+3
+21
+20
All commercial
non-PSB
channels
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
-40
-28
-27
-33
-4
+1
-47
-34
-33
-56
-24
-18
-35
-23
-22
-7
+21
+21
Children’s airtime
commercial PSB
channels
Children’s airtime
children’s
channels
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
-100
-92
-92
-100
-69
-65
-100
-89
-90
-100
-67
-62
-100
-97
-97
-100
-72
-71
Adult airtime
Commercial PSB
channels
83
HFSS advertising restrictions – final review
Adult airtime
commercial PSB
channels
Adult airtime
commercial nonPSB channels
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
-28
-15
-14
+46
+74
+71
-29
-16
-16
+32
+61
+60
-27
-14
-13
+55
+83
+78
Adult airtime –
commercial PSB
portfolio channels
Adult airtime –
music channels
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
2005 HFSS Proxy vs. 2009 HFSS Proxy
2005 Proxy : 2005 vs. 2009
All food and drink
+237
+301
+279
+4
+25
+23
+1
+20
+19
+221
+287
+267
+10
+34
+31
-10
+10
+11
+246
+308
+286
+2
+22
+19
+9
+28
+24
Adult airtime – all
other commercial
non-PSB
channels
Source: Nielsen Media
Note: Minor variations due to rounding
84
HFSS advertising restrictions – final review
Annex 7
7 Changes in the use of advertising
techniques of appeal to children
Introduction
A7.1
In section 6, we provided the key findings of the analysis of changes in the use of
advertising techniques assessed to appeal to children in food and drink advertising.
This annex summarises the analysis and deals in turn with:
a) changes in the volume of advertising spots featuring these advertising
techniques;
b) changes in the volume of advertising impacts featuring these advertising
techniques; and
c) use of each advertising technique by type of content, daypart and by type of
product.
A7.2
It should be noted that:
a) the analysis included in this annex is based on Billet’s data for all food and drink
adverts (i.e. not simply HFSS advertising, which is a subset of all food and drink
advertising) as is not possible to retrospectively apply the nutrient profile model to
determine the nutrient profile status of products in 2005;
b) advertisers make use of the techniques discussed in this annex to promote both
HFSS and non-HFSS products69;
c) the analysis is based on Q1 data for both 2005 and 200970. Inevitably, given the
limited data period, there is a risk that individual advertising campaigns could
have a disproportionately large impact on findings. Similarly the findings are likely
to reflect the seasonality of some food and drink advertising. Therefore the
figures should be regarded as a snapshot, rather than as definitive evidence of
trends;
d) some advertisements make use of more than one of the advertising techniques
calculated to appeal to children, and would therefore be counted more than once
(e.g. in the case of a popular cereal including an offer for children’s books, the
advert would be coded twice; once for the use of a brand equity character and
once for promotions);
e) increases in the use of these creative techniques during adult airtime may not
necessarily be targeted at children;
69
The evidence for this is the continuing presence in children’s airtime of techniques prohibited in advertisements
for HFSS products targeting younger children. It is clear that, in these cases, such techniques are being used to
promote non-HFSS products.
70
The Department of Health stopped commissioning the collection of this data at the end of the first quarter of
2009. To enable a like-for-like comparison, we have compared data for Q1 2009 with data for Q1 2005.
85
HFSS advertising restrictions – final review
f)
advertising spot figures in this section have been rounded to the nearest
thousand; and
g) all data relates to children aged 4-15.
A7.3
The Billetts database contains all food and drink product advertising from 2003 to
March 2009. As full year data is not available for 2009 (the first year that the full
restrictions were implemented) we have, for the purposes of this analysis,
compared data from Q1 2005 and Q1 2009. As explained above, the analysis
should be treated as a snapshot of advertising activity over that period. Analysis of
children’s exposure to food and drink advertising (Annexes 5 and 6) is based on full
year data for 2005 and 2009 sourced from Nielsen Media. Given the differences
between the two databases (see Annex 3) and the analysis periods, it is not
advisable to compare the overall trends in food and drink advertising between the
two sets of analysis – although it does illustrate the general direction of change.
A7.4
The analysis of trends by product category was done to see if particular types of
advertisers are likely to use the different techniques. In 2004, prior to the
development of any nutrient profiling methodology, the FSA highlighted a number of
product categories which were of particular concern. These were referred to as the
‘Big 5’ and consisted of confectionery, soft drinks, cereals, fast food71 and savoury
snacks. The category analysis presented in this annex looks at each of these
categories, which are based on the relevant Billetts sub-categories or combinations
of sub-categories, but also includes dairy products and convenience foods – all
other food and drink advertising has been combined into ‘other’.
Figure A23: Specific Product Category definitions based on Billetts’ sub-categories
Cereals
Foods – Cereals
Ready To Eat
Requiring Preparation
Confectionery
Food – Confectionery
Cereal Bars
Chewing Gum
Chocolate
Sugar Confectionery
Soft Drinks
Drinks – Non-Alcoholic
Carbonated Soft Drinks
Cordials & Squash
Energy Drinks
Fresh Fruit Juice
Milkshakes & Derivatives
Mineral Water
71
The Nielsen Media database, which was used in the 2004 analysis (and subsequent analysis), does not
contain a ‘fast food’ product category. ‘Fast food’ advertising is classified under Nielsen’s ‘Chain Restaurants’
sub-category and has therefore been the label used across all Ofcom’s analysis in this area.
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HFSS advertising restrictions – final review
Dairy
Food – Dairy
Butter/Margarine
Cheese
Cream & Substitutes
Eggs
Milk & Milk Products
Yoghurt/Fromage Frais
Savoury Snacks
Food – Confectionery
Potato Crisps & Snacks
Convenience Foods
Food – Ready To Eat Meals
Baby Food
Dehydrated
Frozen
Convenience Dessert
Fresh Chilled
Microwave
Fast Food
Stores – Other
Fast Food
Restaurants & Bars
Key findings
A7.5
Comparing 2009 to 2005:
a) the Billetts data indicates that there was a 96% increase in food and drink spots
between Q1 2005 and Q1 2009 – over the same period child impacts fell 24%.
Although, for the reasons set out above, this analysis is not directly comparable
with the food and drink analysis presented in Annex 4 and Annex 5 (which is
based on full year data for 2005 and 2009 sourced from Nielsen Media) the
Nielsen data shows total food and drink spots went up 115% between 2005 and
2009 while child impacts fell by 13%;
b) during children’s airtime the volume of spots containing the techniques analysed
fell (with the exception of celebrities) during children’s airtime. By contrast the use
of all of these techniques increased during adult airtime. Overall, with the
exception of licensed characters, the number of food and drink spots featuring
the various creative techniques increased between Q1 2005 and Q1 2009; and
c) overall, children’s exposure to commercials featuring licensed characters,
promotions, brand equity characters and ‘other’ characters fell between Q1 2005
and Q1 2009; however exposure to commercials featuring celebrities and health
claims increased between the two data periods. Exposure to all creative
techniques increased during adult airtime and decreased during children’s
airtime.
87
HFSS advertising restrictions – final review
Overall trends
Food and drink spots
A7.6
The Billetts data suggests that there was a 96% increase in the volume of food and
drink television advertising spots between Q1 2005 and Q1 2009, from 575,000
spots to 1.1m spots. As discussed in previous sections, this increase in the volume
of spots may be partly explained by the rise in the number of commercial television
channels, but may also result from more advertising on existing channels. The
growth in spots was driven by an increase in activity during adult airtime (up 127%),
whereas the number of food and drink advertisements fell by 62% in children’s
airtime as a result of the restrictions introduced in 2007.
Food and drink impacts
A7.7
Over the same period, food and drink impacts among children aged 4-15 fell by
24%, from 3.6bn to 2.7bn, driven by the 78% fall in children’s airtime (from 1.3bn
impacts to 0.3bn impacts). Furthermore, in Q1 2005 the share of all food and drink
impacts represented by exposure during children’s airtime stood at 34.7% - this fell
to 10.2% in Q1 2009. Exposure to food and drink advertising increased marginally
(up 4%) during adult airtime.
Figure A24: Food and drink advertising activity: Q1 2005 vs. Q1 2009
Food and drink spots by airtime
Food and drink impacts by airtime (Children 4-15)
3.6bn
65.3%
1,128
96.8%
2.7bn
89.8%
575
83.7%
34.7%
16.3%
10.2%
3.2%
Change in activity: Q1 2005 vs. Q1 2009
Total Airtime
Adult Airtime
Children’s Airtime
All food and drink – Spots
+96%
+127%
-62%
All food and drink – Impacts
-24%
+4%
-78%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Changes in the volume of food and drink advertising containing specific
techniques
A7.8
88
Figure A25 below summarises changes in the volume of food and drink advertising
spots using the various advertising techniques. Overall, there was a 96% rise in
food and drink spots between Q1 2005 and Q1 2009 – this was led by the 127%
rise during adult airtime, while the number of spots aired during children’s airtime
fell by 62%.
HFSS advertising restrictions – final review
A7.9
The data shows, that with the exception of licensed characters, there was an overall
increase in the use of all techniques between Q1 2005 and Q1 2009 – these
increases were driven by changes in activity during adult airtime. As the data covers
all food and drink, it is important to note that the increased use of all the creative
techniques during adult airtime may be a result of increased use of these
techniques in commercials for HFSS products not directly targeted at children, as
well as increased use in commercials for non-HFSS products.
A7.10
The use of all techniques, except celebrities, fell during children’s airtime – although
as illustrated in the detailed analysis on celebrities, the actual volume of spots using
celebrities during children’s airtime was small and the use of these techniques in
commercials for non-HFSS products is not restricted.
Figure A25: Summary of changes in food and drink spots by creative technique
% change in food and drink advertising spots
by creative technique
Total Airtime
Adult Airtime
Children’s Airtime
All food and drink – Billetts Media
+96%
+127%
-62%
All food and drink – Nielsen Media (2005 vs. 2009)
+115%
+147%
-53%
Celebrity Advertising
+573%
+583%
+245%
Licensed Character Advertising
-23%
+1,869%
-70%
Promotions Based Advertising
+201%
+552%
-67%
Health Claim Advertising
+139%
+156%
-14%
Brand Equity Advertising
+58%
+238%
-59%
Other Character Advertising
+174%
+310%
-5%
Change in Spots Q1 2005 vs. Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Changes in children’s exposure to food and drink advertising containing
specific techniques
A7.11
Between Q1 2005 and Q1 2009, children’s exposure to food and drink advertising
fell by 24%. The 78% decline in impacts during children’s airtime was offset to some
extent by the 4% rise in impacts during adult airtime.
A7.12
As shown in Figure A26 below, children’s exposure to food and drink commercials
featuring celebrities and health claims increased between Q1 2005 and Q1 2009,
whereas exposure to the other advertising techniques analysed fell. Food and drink
impacts for all of the advertising techniques increased during adult airtime;
particularly for commercials using celebrities and promotions. There was a
reduction in impacts for all techniques during children’s airtime.
89
HFSS advertising restrictions – final review
Figure A26: Summary of changes in food and drink impacts by creative technique
% change in food and drink impacts by
creative technique (Children 4-15)
Total Airtime
Adult Airtime
Children’s Airtime
All food and drink – Billetts Media
-24%
+4%
-78%
All food and drink – Nielsen Media (2005 vs. 2009)
-13%
+17%
-72%
+143%
+153%
-4%
Licensed Character Advertising
-84%
+69%
-88%
Promotions Based Advertising
-41%
+112%
-82%
Health Claim Advertising
+18%
+36%
-40%
Brand Equity Advertising
-56%
+72%
-82%
Other Character Advertising
-2%
+36%
-26%
Change in Impacts Q1 2005 vs. Q1 2009
Celebrity Advertising
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
A7.13
Figure A25 and Figure A26 show that while the use of promotions-based
advertising, brand equity characters and other characters increased as a result of
more spots being aired in adult airtime, children’s overall exposure to commercials
featuring these techniques declined. Furthermore, while the overall level of food and
drink spots featuring licensed characters declined by 23%, exposure to these
commercials fell at a faster rate, by 84%. The marked increase in adult airtime was
offset by the decline in children’s airtime.
A7.14
These findings could suggest that the growth in advertising activity in adult airtime is
not necessarily being used to ‘target’ children. The two techniques (celebrity
advertising and health claims) to which exposure increased were already more
likely to be used in adult airtime prior to the content restrictions being implemented
– suggesting these techniques maybe more likely to be used in commercials for
products of particular appeal to adults and therefore any increased activity maybe
driven by these types of products.
A7.15
Furthermore, while the use of brand equity characters and other characters has not
been restricted in children’s airtime, the decline in the number of spots using these
techniques is likely to be as a result of the restrictions in HFSS advertising during
this airtime – commercials for HFSS products that may have previously used these
techniques can no longer feature during children’s airtime, resulting in a decline in
the use of these techniques.
Changes in the volume of spots by product category
A7.16
72
Figure A27 below shows the volume of, and exposure to, food and drink advertising
by product category72. The analysis shows there were above-average increases in
The analysis of trends by product category has been conducted to provide more detail around which particular
types of advertisers are likely to use the different techniques. In 2004, prior to the development of any nutrient
profiling methodology, the FSA highlighted a number of product categories which were of particular concern –
72
these were referred to as the ‘Big 5’ and consisted of confectionery, soft drinks, cereals, fast food and savoury
snacks. The category analysis presented here is based on these categories but also includes dairy products and
convenience foods – all other food and drink advertising has been combined into ‘other’.
90
HFSS advertising restrictions – final review
the volume of cereal and chain restaurant advertising spots between Q1 2005 and
Q1 2009.
A7.17
Advertising spots for cereal products increased by 122%, from 72,000 to 160,000 in
Q1 2009. Chain restaurants spots increased from 49,000 in Q1 2005 to 116,000 in
Q1 2009 – a rise of 137%.
Changes in children’s exposure by product category
A7.18
Child impacts fell across all product categories, although lower than average falls
were observed across the dairy and chain restaurant categories. While overall
exposure to food and drink advertising fell by 24%, impacts for commercials
featuring dairy products fell 13% and for chain restaurants fell by 17%.
A7.19
While this analysis is based on the advertising of all food and drink products across
all airtime, our analysis in Annex 5 highlights that a number of commercials for
McDonalds (which would be classified under the ‘chain restaurants’ category) were
certified as advertising non-HFSS products. It is therefore necessary to exercise
some caution in interpreting the below-average fall in children’s exposure to chain
restaurant advertising as this will include commercials for both HFSS and nonHFSS products.
Figure A27: Food and drink activity by product category
Food and drink spots by category
Food and drink impacts by category
(Children 4-15)
3.6bn
2.7bn
575
Spots
Impacts,
Children 4-15
All food and drink
commercials
+96
-24
Conf ectionery
+95
-35
Sof t drinks
+62
-27
Cereals
+122
-32
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
1,128
Dairy
+64
-13
Convenience
+34
-29
Chain restaurants
+137
-17
Savoury snacks
+46
-57
Other
+117
-19
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Changes in the use of creative techniques by airtime, daypart and
product categories
Celebrities
Summary - Spots
A7.20
Between Q1 2005 and Q1 2009 there was an increase in the volume of food and
drink commercials featuring celebrities. The data in Figure A28 shows 25,000
91
HFSS advertising restrictions – final review
(4.3%) of the 575,000 food and drink spots aired in Q1 2005 were for commercials
featuring a celebrity – this rose to 168,000 spots in Q1 2009 (14.9% of all food and
drink advertising).
Summary - Impacts
A7.21
Over the same period, child impacts for food and drink advertisements featuring a
celebrity increased from 0.2bn to 0.4bn impacts, accounting for 14.8% of all food
and drink impacts in Q1 2009 compared with 4.6% in Q1 2005.
Figure A28: Celebrities: Overall change in spots and impacts
Food and drink spots: Celebrity advertising
Food and drink impacts: Celebrity advertising
(Children 4-15)
3.6bn
1,128
4.6%
95.4%
14.9%
85.1%
2.7bn
2,69
9
14.8%
85.2%
575
4.3%
95.7%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.22
Overall, spots featuring a celebrity increased by 573% (Figure A29), driven by the
significant increase during adult airtime from 24,000 spots to 166,000 spots (up
583%). The majority of food and drink commercials featuring a celebrity continue to
be aired during adult airtime, with 98.5% in Q1 2009). This may suggest that this
particular technique may be more likely to be used in commercials for products
more likely to appeal to adults. In line with the interim review the majority of
celebrities featured in these advertisements during Q1 2009 appeared to be of
primary appeal to adults (e.g. Ian Botham, Gloria Hunniford).
A7.23
Although figures suggest an increase in the use of this technique during children’s
airtime, the actual number of spots remains very small and would be for non-HFSS
advertising.
Impacts by airtime
A7.24
Impacts for food and drink commercials featuring a celebrity rose by 143%, from
0.2bn in Q1 2005 to 0.4bn impacts in Q1 2009.
A7.25
Adult airtime accounted for 97.3% of all celebrity advertising impacts in Q1 2009 –
up from 93.2% in Q1 2005. The overall increase in exposure to this type of
92
HFSS advertising restrictions – final review
advertising was driven by activity in adult airtime during which impacts increased by
153% from 0.15bn to 0.39bn.
Figure A29: Celebrities: Spots and impacts by airtime
Food and drink spots by airtime:
Celebrity advertising
Food and drink impacts by airtime:
Celebrity advertising (Children 4-15)
168
0.40bn
98.5%
97.3%
0.17bn
93.2%
25
97.1%
2.9%
6.8%
1.5%
Change in activity: Q1 2005 vs. Q1 2009
Total Airtime
Adult Airtime
Children’s Airtime
Celebrity Advertising - Spots
+573%
+583%
+245%
Celebrity Advertising – Impacts
+143%
+153%
-4%
2.7%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.26
The growth in the use of commercials featuring celebrities was spread across all
dayparts in adult airtime.
A7.27
The volume of food and drink spots featuring celebrities aired after 18:00 increased
from 15,000 in Q1 2005 to almost 100,000 in Q1 2009 – however as a proportion of
all celebrity based food and drink spots in adult airtime the proportion aired after
18:00 fell slightly from 62.0% to 60.2% due to substantial growth throughout the
earlier dayparts.
Impacts by daypart
A7.28
Similarly children’s exposure to celebrities in food and drink commercials increased
across all dayparts during adult airtime. The number of impacts delivered after
18:00 increased from 0.1bn to 0.3bn impacts – although the share of all celebrity
food and drink impacts in adult airtime delivered across these dayparts fell from
74.8% in Q1 2005 to 68.7% in Q1 2009.
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HFSS advertising restrictions – final review
Figure A30: Celebrities: Spots and impacts by daypart in adult airtime
Food and drink impacts in ‘adult’ airtime:
Celebrity advertising (Children 4-15)
Food and drink spots in ‘adult’ airtime:
Celebrity advertising
166
0.39bn
0.15bn
24
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by product category
A7.29
The rise in the number of celebrity spots was driven by increased advertising
activity within the dairy and ‘other’ food and drink product categories.
A7.30
While there were no dairy commercials featuring a celebrity in Q1 2005, this
category accounted for 49,000 spots in Q1 2009. Spots for products in the ‘other’
category increased from 7,000 in Q1 2005 to 81,000 in Q1 2009.
Impacts by product category
A7.31
Similarly, the increase in children’s exposure to celebrities in food and drink
commercials was driven by the dairy and ‘other’ food and drink categories. Dairy
advertising accounted for 0.1bn impacts in Q1 2009 and the ‘other’ product
category represented 0.2bn impacts in Q1 2009, up by 262% from 0.05bn in Q1
2005.
Figure A31: Celebrities: Spots and impacts by product category
Food and drink spots by category:
Celebrity advertising
Food and drink impacts by category:
Celebrity advertising (Children 4-15)
168
0.40bn
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
Spots
Impacts,
Children 4-15
All commercials
featuring celebrities
+573
+143
Conf ectionery
+379
+175
Sof t drinks
0.17bn
25
*
*
+64
-28
Dairy
*
*
Convenience
-
-
-100
-100
Cereals
Chain restaurants
Savoury snacks
Other
+58
-48
+1051
+262
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
94
HFSS advertising restrictions – final review
Licensed characters
Summary – Spots
A7.32
The use of licensed characters accounted for 4.3% (25,000 spots) of food and drink
spots in Q1 2005 – this fell to 1.7% (19,000 spots) of all food and drink spots in Q1
2009.
Summary – Impacts
A7.33
Over the same period the share of all food and drink impacts that featured a
licensed character fell from 10.7% (0.4bn impacts) to 2.2% (0.1bn impacts).
Figure A32: Licensed characters: Overall change in spots and impacts
Food and drink spots: Licensed characters
Food and drink impacts: Licensed characters
(Children 4-15)
3.6bn
10.7%
1,128
1.7%
98.3%
89.3%
2.7bn
2.2%
97.8%
575
4.3%
95.7%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.34
The volume of food and drink spots featuring a licensed character fell by 23% from
25,000 in Q1 2005 to 19,000 in Q1 2009. This overall decline in food and drink
spots featuring licensed characters was driven by the reduction in spots during
children’s airtime, as there was an increase in such advertising during adult airtime.
As a result the share of food and drink spots featuring licensed characters
accounted for by adult airtime increased from 2.4% of all such commercials in Q1
2005 to 61.6% in Q1 2009.
Impacts by airtime
A7.35
Impacts for food and drink commercials using a licensed character fell by 84% from
0.39bn to 0.06bn impacts in Q1 2005 – this was driven by the marked decline
during children’s airtime.
A7.36
While impacts during adult airtime increased, they did so at a slower rate (up 69%)
than the increase in the volume of spots aired during this airtime (up 1,869%).
Although this increase in the use of licensed characters in adult airtime was
significant, the overall reduction in the use of this technique, the significant
95
HFSS advertising restrictions – final review
reduction in exposure, and the slower growth of child impacts in adult airtime, may
suggest that the increase in advertising activity during adult airtime is not targeted
at children.
Figure A33: Licensed characters: Spots and impacts by airtime
Food and drink spots by airtime:
Licensed characters
Food and drink impacts by airtime:
Licensed characters (Children 4-15)
0.39bn
25
2.5%
97.5%
2.4%
97.6%
19
61.6%
38.4%
0.06bn
27.1%
72.9%
Change in activity: Q1 2005 vs. Q1 2009
Total Airtime
Adult Airtime
Children’s Airtime
Licensed Character Advertising – Spots
-23%
+1,869%
-70%
Licensed Character Advertising - Impacts
-84%
+69%
-88%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.37
Adult airtime accounted for a small amount of licensed character food and drink
commercials in Q1 2005 and the increase in activity in Q1 2009 was distributed
across all dayparts. With this increased activity during adult airtime, the share of
food and drink spots featuring a licensed character aired after 18:00 increased from
6.4% to 57.3%.
Impacts by daypart
A7.38
96
Impacts for this type of advertising fell dramatically during the 06:00-09:30 slot;
however there was an increase in exposure across all other dayparts as a result of
increased advertising activity across these dayparts. The share of impacts for food
and drink commercials featuring a licensed character that were delivered after
18:00 increased from 3.2% to 58.5%, accounting for 9.6m impacts in Q1 2009.
HFSS advertising restrictions – final review
Figure A34: Licensed characters: Spots and impacts by daypart in adult airtime
Food and drink impacts in ‘adult’ airtime:
Licensed characters (Children 4-15)
Food and drink spots in ‘adult’ airtime:
Licensed characters
16.3m
11.7
9.7m
0.6
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by product category
A7.39
Although the use of licensed characters fell overall between the two analysis
periods, there was an increase in the use of this technique by dairy product
advertisers and those in the ‘other’ category, with a fall in use among cereal and
chain restaurants advertisers.
A7.40
Dairy products accounted for 6,000 spots in Q1 2009 and the ‘other’ product
category accounted for 10,000 spots – together the two categories represented
87.3% of food and drink commercials with a licensed character in Q1 2009.
Impacts by product category
A7.41
Similarly the fall in impacts was led by the significant drop in exposure to cereal and
chain restaurant commercials using this technique.
Figure A35: Licensed characters: Spots and impacts by product category
Food and drink spots by category:
Licensed characters
25
Food and drink impacts by category:
Licensed characters (Children 4-15)
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
0.39bn
19
Spots
Impacts,
Children 4-15
All commercials
featuring licensed
characters
-23
-84
Conf ectionery
-100
-100
Sof t drinks
-30
-88
Cereals
-100
-100
+2589
+1346
Dairy
Convenience
0.06bn
Chain restaurants
-
-
-90
-91
Savoury snacks
-
-
Other
*
*
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
97
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Promotions
Summary – Spots
A7.42
Promotions based food and drink advertising accounted for 11.1% (125,000 spots)
of all food and drink advertising spots in Q1 2009 – up from 7.2% (42,000 spots) in
Q1 2005.
Summary – Impacts
A7.43
Over the same period the share of all food and drink impacts containing promotions
fell from 13.2% (0.5bn impacts) to 10.3% (0.3bn impacts). This reduction in child
impacts suggests the increase in spots observed over the same period may not
necessarily be targeted at children.
Figure A36: Promotions: Overall change in spots and impacts
Food and drink spots: Promotions based
Food and drink impacts: Promotions based
(Children 4-15)
3.6bn
13.2%
1,128
11.1%
88.9%
86.8%
2.7bn
10.3%
89.7%
575
7.2%
92.8%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.44
43.3% (18,000 spots) of food and drink spots containing promotions were aired
during adult airtime in Q1 2005 – this figure rose to 93.8% (118,000 spots) in Q1
2009. The significant increase in the use of this technique during adult airtime
(spots up 552%) offset the decline in such spots observed during children’s airtime
(down 67%), resulting in an overall increase in spots of 201%.
Impacts by airtime
A7.45
98
In Q1 2005, 21.3% of child impacts for commercials featuring a promotion were
delivered in adult airtime – the corresponding figure in Q1 2009 was 75.9%.
Although children’s exposure to this technique fell overall by 41% (from 0.5bn
impacts to 0.3bn impacts), the effect of the 82% fall in impacts during children’s
airtime (from 0.4bn to 0.1bn impacts) was limited due to an increase of 112% (from
0.1bn impacts to 0.2bn impacts) during adult airtime.
HFSS advertising restrictions – final review
Figure A37: Promotions: Spots and impacts by airtime
Food and drink spots by airtime:
Promotions based
Food and drink impacts by airtime:
Promotions based (Children 4-15)
125
0.47bn
93.8%
21.3%
78.7%
0.28bn
75.9%
42
43.3%
56.7%
24.1%
6.2%
Change in activity: Q1 2005 vs. Q1 2009
Promotions Based Advertising – Spots
Promotions Based Advertising - Impacts
Total Airtime
Adult Airtime
Children’s Airtime
+201%
+552%
-67%
-41%
+112%
-82%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.46
As observed across the other techniques, the growth in the use of promotionsbased food and drink advertising during adult airtime was distributed across all
dayparts. The proportion of these spots aired after 18:00 in adult airtime fell
marginally from 55.4% (10,000 spots) in Q1 2005 to 53.2% (63,000 spots) in Q1
2009.
Impacts by daypart
A7.47
The increase in impacts for commercials featuring a promotion delivered during
adult airtime was also spread across the dayparts with the exception of the 06:0009:30 slot, during which impacts fell from 12m in Q1 2005 to 10m in Q1 2009.
Figure A38: Promotions: Spots and impacts by daypart in adult airtime
Food and drink spots in ‘adult’ airtime:
Promotions based
Food and drink impacts in ‘adult’ airtime:
Promotions based (Children 4-15)
0.21bn
118
0.10bn
18
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
99
HFSS advertising restrictions – final review
Spots by product category
A7.48
The increase in food and drink advertisements containing promotions between Q1
2005 and Q1 2009 was driven by dairy and ‘other’ products. Around 20,000 dairy
product commercials featuring a promotion aired in Q1 2009 and 89,000
commercials for ‘other’ products using this technique.
Impacts by product category
A7.49
While there was an increase in children’s exposure to the dairy and ‘other’ product
category commercials containing promotions, the overall decline in promotionsbased impacts was driven by a reduction in the use of the technique by
confectionery, cereal, chain restaurant and savoury snack advertisers.
Figure A39: Promotions: Spots and impacts by product category
Food and drink spots by category:
Promotions based
125
Food and drink impacts by category:
Promotions based (Children 4-15)
0.47bn
0.28bn
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
Spots
Impacts,
Children 4-15
All promotions
based commercials
+201
-41
Conf ectionery
-100
-100
Sof t drinks
42
Cereals
Dairy
Convenience
Chain restaurants
Savoury snacks
Other
*
*
-44
-90
+8505
+2311
-
-
-42
-65
-100
-100
+2396
+693
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Health claims
Summary – Spots
A7.50
Food and drink commercials carrying a health claim increased from 119,000 in Q1
2005 to 283,000 in Q1 2009. As a share of all food and drink advertising, those
containing a health claim accounted for 20.6% of food and drink spots in Q1 2005
and 25.1% in Q1 2009.
Summary – Impacts
A7.51
100
While overall exposure to food and drink advertising among children fell between
the two periods, this audience saw more commercials featuring a health claim.
Impacts increased in volume terms from 0.7bn to 0.8bn – and in share terms from
18.7% to 29.1% of all food and drink impacts.
HFSS advertising restrictions – final review
Figure A40: Health claims: Overall change in spots and impacts
Food and drink spots: Health claims
Food and drink impacts: Health claims
(Children 4-15)
3.6bn
18.7%
1,128
25.1%
81.3%
2.7bn
29.1%
74.9%
70.9%
575
20.6%
79.4%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.52
In both periods the majority of commercials containing a health claim were shown in
adult airtime – representing 90% (107,000 spots) of food and drink spots aired in
Q1 2005 and 96.4% (273,000 spots) in Q1 2009. This could suggest that this type
of advertising may be used in commercials for products more likely to appeal to
adults.
A7.53
Although spots during children’s airtime fell 14% between the two periods, this
decline was offset by the 156% increase in spots containing health claims during
adult airtime, resulting in an overall increase of 139%.
Impacts by airtime
A7.54
Although the use of, and exposure to, food and drink advertising containing health
claims fell during children’s airtime (down 40%), the 36% growth in impacts during
adult airtime led to an overall increase in children’s exposure to food and drink
commercials with a health claim (up 18%).
A7.55
The majority of children’s exposure to this creative technique took place in adult
airtime which accounted for 87.7% (0.7bn impacts) in Q1 2009 up from 75.7% in Q1
2005.
101
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Figure A41: Health claims: Spots and impacts by airtime
Food and drink impacts by airtime:
Health claims (Children 4-15)
Food and drink spots by airtime:
Health claims
0.79bn
283
87.7%
96.4%
0.67bn
75.7%
119
90.0%
24.3%
12.3%
3.6%
10.0%
Change in activity: Q1 2005 vs. Q1 2009
Total Airtime
Adult Airtime
Children’s Airtime
Health Claim Advertising – Spots
+139%
+156%
-14%
Health Claim Advertising - Impacts
+18%
+36%
-40%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.56
The increase in the volume of commercials featuring a health claim was distributed
across all dayparts during adult airtime. Although the majority of health claim spots
were aired after 18:00, the share of spots shown during this daypart remained
steady – 60.2% (64,000 spots) in Q1 2005 and 59.7% (163,000 spots) in Q1 2009.
Impacts by daypart
A7.57
Similarly, the share of health claim impacts delivered after 18:00 stood at 70.9%
(0.4bn impacts) in Q1 2005 and 68.5% (0.5bn impacts) in Q1 2009.
Figure A42: Health claims: Spots and impacts by daypart in adult airtime
Food and drink spots in ‘adult’ airtime:
Health claims
Food and drink impacts in ‘adult’ airtime:
Health claims (Children 4-15)
273
0.69bn
0.51bn
107
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
102
HFSS advertising restrictions – final review
Spots by product category
A7.58
As Figure A43 illustrates there was an increase in the use of commercials featuring
a health claim across a number of product categories – however there were aboveaverage increases in activity by convenience food (up 173%) and ‘other’ product
(up 541%) advertisers. Dairy product commercials accounted for the greatest
number of food and drink commercials using a health claim (89,000 spots in Q1
2009).
Impacts by product category
A7.59
Similarly, there were above-average increases in children’s exposure to this type of
advertising across the convenience food (up 137%) and ‘other’ product category (up
130%) commercials – however dairy commercials using this technique accounted
for the largest number of impacts delivered (0.25bn impacts).
Figure A43: Health claims: Spots and impacts by product category
Food and drink spots by category:
Health claims
Food and drink impacts by category:
Health claims (Children 4-15)
283
0.79bn
0.67bn
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
Spots
Impacts,
Children 4-15
All commercials with
a health claim
+139
+18
Conf ectionery
119
*
*
Sof t drinks
+68
-28
Cereals
+126
-11
Dairy
+62
0
Convenience
+173
+137
Chain restaurants
*
*
Savoury snacks
-100
-100
Other
+541
+130
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Brand equity characters
Summary – Spots
A7.60
Between Q1 2005 and Q1 2009 the number of food and drink spots featuring brand
equity characters increased from 66,000 (11.5% of all food and drink spots) to
105,000 (9.3% of all food and drink spots).
Summary – Impacts
A7.61
Over the same period there was an overall reduction in children’s exposure to this
technique in food and drink advertising. Impacts for such commercials fell from
0.7bn (18.7% share of all food and drink impacts) to 0.3bn (10.8% share). This
disparity between a decline in child impacts for commercials containing a brand
equity character and an increase in spots using this technique could suggest this
change in activity is not necessarily targeted at children.
103
HFSS advertising restrictions – final review
Figure A44: Brand equity: Overall change in spots and impacts
Food and drink impacts: Brand equity
(Children 4-15)
Food and drink spots: Brand equity
3.6bn
18.7%
1,128
2.7bn
9.3%
81.3%
90.7%
10.8%
89.2%
575
11.5%
88.5%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.62
Despite a 59% fall in the number of brand equity food and drink spots in children’s
airtime, the overall volume of these spots has increased by 58%, driven by the use
of the technique in adult airtime. As a result adult airtime accounted for 84.4% of all
brand equity food and drink spots in Q1 2009 compared with just 39.4% in Q1 2005.
Impacts by airtime
A7.63
Children’s exposure to food and drink commercials featuring a brand equity
character fell by 56% between Q1 2005 (0.7bn impacts) and Q1 2009 (0.3bn
impacts). This decline was led by the fall in exposure during children’s airtime which
accounted for 0.6bn impacts (83.0%) of all food and drink brand equity impacts in
Q1 2005 and 0.1bn impacts (33.5%) in Q1 2009.
A7.64
The increase in spots during adult airtime led to a 72% increase in children’s
exposure during this airtime from 0.1bn impacts to 0.2bn impacts and accounted for
two-thirds of all brand equity impacts in Q1 2009.
104
HFSS advertising restrictions – final review
Figure A45: Brand equity: Spots and impacts by airtime
Food and drink spots by airtime:
Brand equity
Food and drink impacts by airtime:
Brand equity (Children 4-15)
105
0.67bn
84.4%
17.0%
83.0%
66
39.4%
0.29bn
66.5%
60.6%
15.6%
33.5%
Change in activity: Q1 2005 vs. Q1 2009
Total Airtime
Adult Airtime
Children’s Airtime
Brand Equity Advertising – Spots
+58%
+238%
-59%
Brand Equity Advertising - Impacts
-56%
+72%
-82%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.65
The increase during adult airtime in the use of advertising spots featuring a brand
equity character was distributed across all dayparts. In both periods, the majority of
these commercials were aired after 18:00 – accounting for 58.6% of spots (52,000
spots) in Q1 2009, up slightly from 55.0% (14,000 spots) in Q1 2005.
Impacts by daypart
A7.66
The post-18:00 dayparts also accounted for the majority of impacts, increasing from
64.4% (0.07bn impacts) of all food and drink impacts featuring a brand equity
character in Q1 2005 to 69.2% (0.14bn impacts) in Q1 2009.
Figure A46: Brand equity: Spots and impacts by daypart in adult airtime
Food and drink spots in ‘adult’ airtime:
Brand equity
Food and drink impacts in ‘adult’ airtime:
Brand equity (Children 4-15)
88
0.20bn
0.11bn
26
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
105
HFSS advertising restrictions – final review
Spots by product category
A7.67
The use of brand equity characters increased notably among cereal (up 55%), dairy
(up 112%) and ‘other’ product (up 162%) advertisers with dairy commercials
accounting for the greatest number of these types of commercials in Q1 2009
(45,000 spots).
Impacts by product category
A7.68
However the increase in cereal and ‘other’ product commercials featuring brand
equity characters did not lead to a subsequent increase in exposure. There was a
decline in children’s exposure to this advertising technique across all product
categories with the exception of dairy products. Impacts for dairy product
advertising featuring a brand equity character increased from 0.14bn impacts to
0.15bn impacts – a rise of 8%.
Figure A47: Brand equity: Spots and impacts by product category
Food and drink spots by category:
Brand equity
105
Food and drink impacts by category:
Brand equity (Children 4-15)
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
0.67bn
All commercials
featuring a brand
equity character
66
Conf ectionery
Sof t drinks
0.29bn
Spots
Impacts,
Children 4-15
+58
-56
+3
-84
*
*
Cereals
+55
-77
Dairy
+112
+8
Convenience
-100
-100
Chain restaurants
-100
-100
Savoury snacks
-100
-100
Other
+162
-16
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Other characters
Summary – Spots
A7.69
The number of food and drink spots featuring other types of characters increased
from 34,000 spots in Q1 2005 to 92,000 in Q1 2009 – the share of all food and drink
spots using this technique also increased from 5.8% to 8.2% over the same period.
Summary – Impacts
A7.70
106
Children’s exposure to this type of advertising remained unchanged between the
two periods (0.3bn impacts), but (as a result of the overall decline in food and drink
impacts) impacts for advertisements containing other characters accounted for a
greater share of all food and drink impacts, up from 8.9% to 11.6%. The disparity
between unchanged in child impacts for commercials containing other characters
HFSS advertising restrictions – final review
and an increase in spots using this technique could suggest this growth in
advertising activity is not necessarily targeted at children
Figure A48: Other characters: Overall change in spots and impacts
Food and drink spots: Other character advertising
Food and drink impacts: Other character advertising
(Children 4-15)
3.6bn
8.9%
1,128
8.2%
91.8%
91.1%
2.7bn
11.6%
88.4%
575
5.8%
94.2%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by airtime
A7.71
The overall increase in the volume of spots featuring other characters (up 174%
from 34,000 spots to 92,000 spots) was driven by activity during adult airtime (up
310% from 19,000 spots to 79,000 spots), while spots during children’s airtime fell
slightly (down 5%).
Impacts by airtime
A7.72
Although child impacts remained fairly stable between the two periods (down 2%),
the increased use of this technique during adult airtime led to an increase in
children’s exposure to advertisements containing other characters during this
airtime (up 36%) and consequently growth in share (from 38.6% in Q1 2005 to
53.6% in Q1 2009).The volume of impacts in children’s airtime shows that this
technique is being used by some advertisers to promote non HFSS products.
107
HFSS advertising restrictions – final review
Figure A49: Other characters: Spots and impacts by airtime
Food and drink spots by airtime:
Other character advertising
Food and drink impacts by airtime:
Other character advertising (Children 4-15)
92
85.1%
0.32bn
0.31bn
38.6%
53.6%
61.4%
34
46.4%
56.9%
43.1%
14.9%
Change in activity: Q1 2005 vs. Q1 2009
Other Character Advertising – Spots
Other Character Advertising - Impacts
Total Airtime
Adult Airtime
+174%
+310%
Children’s Airtime
-5%
-2%
+36%
-26%
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
Spots by daypart
A7.73
The number of commercials featuring other characters increased across all
dayparts during adult airtime. The majority of spots were aired post-18:00 – these
dayparts accounted for 57.1% (11,000 spots) of all other character spots in adult
airtime during Q1 2005 compared with 56.8% (45,000 spots) in Q1 2009.
Impacts by daypart
A7.74
Children’s exposure to this type of advertising increased across all dayparts with the
exception of the 06:00-09:30 slot (down 23%) - the largest increase occurred during
the 15:15-17:00 daypart (up 153%).
Figure A50: Other characters: Spots and impacts by daypart in adult airtime
Food and drink spots in ‘adult’ airtime:
Other character advertising
Food and drink impacts in ‘adult’ airtime:
Other character advertising (Children 4-15)
0.17bn
79
0.12bn
19
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
108
HFSS advertising restrictions – final review
Spots by product category
A7.75
The growth in the use of other types of characters was driven by above-average
increases in activity among confectionery (up 1064%), soft drinks (up 828%), cereal
(up 207%) and chain restaurant (up 214%) advertisers. Confectionery products
accounted for the greatest number of these types of commercials shown in Q1 2009
(30,000 spots).
Impacts by product category
A7.76
While children’s exposure to this type of advertising remained fairly consistent
between the two periods, there was a fall in savoury snack and cereal impacts
(despite an increase in cereal spots between Q1 2005 and Q1 2009) and a rise in
confectionery, soft drinks and chain restaurant impacts.
Figure A51: Other characters: Spots and impacts by product category
Food and drink spots by category:
Other character advertising
92
Food and drink impacts by category:
Other character advertising (Children 4-15)
0.32bn
0.31bn
% change in food
and drink activity,
Q1 2005 vs. Q1 2009
All commercials
featuring ‘other
characters’
Conf ectionery
34
Spots
Impacts,
Children 4-15
+174
-2
+1064
+98
Sof t drinks
+828
+258
Cereals
+207
-42
Dairy
+62
+9
Convenience
-
-
Chain restaurants
+214
+421
Savoury snacks
-100
-100
Other
-36
-88
‘-’ Denotes those categories where there was no activity
in either periods
‘*’ Denotes those categories where there was no activity
in Q12005 but there was in Q1 2009
Source: Billetts Media Monitoring
Note: Minor variations due to rounding
A7.77
The following table summarises the use of, and children’s exposure to, each of the
advertising techniques detailed above.
109
HFSS advertising restrictions – final review
Figure A52: Summary of changes in the use of creative techniques
Spots, 000s
Total Airtime
Adult airtime
Children’s airtime
Q1
2005
Q1
2009
%
change
Q1
2005
Q1
2009
%
change
Q1
2005
Q1
2009
%
change
Spots, 000s
575
1,128
+96
482
1,092
+127
94
36
-62
Impacts, bn
3.6
2.7
-24
2.4
2.4
+4
1.3
0.3
-78
Spots, 000s
25
168
+573
24
166
+583
1
2
+245
Impacts, bn
0.2
0.4
+143
0.15
0.39
+153
0.01
0.01
-4
Spots, 000s
25
19
-23
1
12
+1,869
24
7
-70
Impacts, bn
0.4
0.1
-84
0.01
0.02
+69
0.38
0.04
-88
Spots, 000s
42
125
+201
18
118
+552
24
8
-67
Impacts, bn
0.5
0.3
-41
0.10
0.21
+112
0.37
0.07
-82
Spots, 000s
119
283
+139
107
273
+156
12
10
-14
Impacts, bn
0.7
0.8
+18
0.51
0.69
+36
0.16
0.10
-40
Spots, 000s
66
105
+58
26
88
+238
40
16
-59
Impacts, bn
0.7
0.3
-56
0.11
0.20
+72
0.59
0.10
-82
Spots, 000s
34
92
+174
19
79
+310
14
14
-5
Impacts, bn
0.3
0.3
-2
0.12
0.17
+36
0.20
0.15
-26
All food and drink
Celebrity advertising
Licensed character advertising
Promotions based advertising
Health claim advertising
Brand equity advertising
Other character advertising
110